IBurskk Tamm

from GWP Realty ltrachelgwprealtycomgt Sent Friday July 31 2020 100 PM 2020JUL 31 PH I r3 To Young Anthony W tabbassi01gmailcom Subject FW Request for Meeting Attachments Dr Abbassi-3766 Ocean Drive Vero Beach Propertypdf Global Retreatspdf

SECURITY WARNING This message has originated from an EXTERNAL SOURCE Please show caution when clicking links opening attachments or respondin to this email unless you reco nize the sender and know the content is safe

Hello Mayor Young Hope this email finds you well I am writing on behalf of my friend Dr Tony Abbassi a Vero Beach Property Owner who was unfortunately mixed up unbeknownst to him in a city fine issue because his property manager was not aware of the citys rental policy As Dr Abbassi and his wife are very busy running the Primary Care Practice they hired a Property Management Company to rent the property and they inappropriately rented the property through Short term rentals Dr Abbassi was not aware and furthermore the notices kept going to a property they no longer owned Therefore the notices were not received and the fines kept increasing

We have been in communication with the City Manager Mr Falls and in his email that I am attaching below he said to send an offer to reduce the fine to be considered in the next City Council Meeting Attached please find said offer As time is of the essence and with a storm looming we would like for you to have the offer as well and hope that you consider this case to be heard at the next City Council Meeting on August 18

Dr Abbassi is a pillar of the community and has never turned away from anyone in their time of need Hopefully the City of Vero Beach will do the same during these difficult times

We look forward to hearing from you to make this happen

Best

20801 Blvd Fi 33180

Rachei Fresco

T 305-519-3630 T 954 734-2912 F 786-5240657

1

July 31 2020

Monte K Falls PE City Manager City of Vero Beach 1053 20th Place Vero Beach FL 32960

Re Dr Tony and Lorangel Abbassi CASE 17-CE-7330 I 1034M Case 18-CE-8775 1508M - Request for Amendment of Penalty for Violations at 3766 Ocean Drive Vero Beach Florida 32963

Dear City Manager Falls

Pursuant to your email instructions of July 22 2020 we respectfully request that the City Council consider an amendment to the amount due of approximately $428000 as established by the Code Enforcement Board As you can see in your files we have already paid the fine for the lighting 1470M18-CE-8702

As context under Section 775 083 ofthe Florida Statutes if a criminal is convicted ofa life felony (such as murder) the fine imposed is $15000 If a criminal is convicted of a first-degree felony (such as rape) the fine is $10000 If there is a pecuniary gain from the offense the maximum penalty that is to be imposed is double the pecuniary gain derived from the offense

As you can see from the attached statement from Global Retreats the management company that was supposed to manage the property in accordance with the law the property derived total rental income of $74300 for the years 2017-20 I 8 and beginning 2019 This is the relevant time period of the offense

Using the double the pecuniary gain derived from the offense standard articulated by the Florida Statutes and the Florida Constitution based on the gain it would be unfair and manifestly unjust to impose a fine upon us of any more than $150000 I cite this statute not to say that the council acted unlawfully but to provide you with some perspective as to how unfair it is that my fine is more than twice and larger than if I committed a crime and in this case it was a civil infraction

We had a mortgage of $18 million on the property and when we sold the house we had an insurmountable debt due to the mortgage payments utilities maintenance taxes and insurance When the house was sold we had to borrow additional money to pay for the closing commission and back-payments for utilities We are now in a dire financial situation when taking into consideration the mortgage and all of the expenses associated with the house (including the fine)

In addition for the last 5 months our primary care practice has been completely disrupted by the COVID-19 pandemic and we have been concentrating solely on treating patients in hospitals stricken with COVID-19 at far less revenue to our medical practice

We are respectfully requesting the imposition of a reasonable adjustment to the fine imposed by the City Council that is consistent with the letter and the spirit of the Florida Statutes and the Florida Constitution We are very reputable individuals who simply never received the Citys notices Had the notices gone directly to our residence there is zero doubt that we would have taken care of the problem that the Property Management company caused We gave them the house to rent and unbeknownst to us the property manager was renting the property in an unauthorized manner

During this whole time we were very busy with our medical practice and we hired the property management company to take care of the rental property and trusted them to do the right thing We are law-abiding citizens with a spotless record (absent this fine) and a very well-respected medical practice that is beloved by our patients who we treat as our family members

As stated earlier this Vero Beach property had a great amount of debt that still has to be paid off

CONCLUSION

In sum we are offering to pay back double the pecuniary gain derived from the offense as contemplated by the Florida Statutes which in this case would be a $150000 settlement In addition I will gladly donate the remainder of the fine via donation of my time to the Treasure Coast Community Health Center in Vero Beach FL I am willing to work and provide 50 hours of medical consultations each year for the next 2 years at the Community Health Center to provide free high quality medical care to the people of Vero Beach FL who lack financial resources to receive this assistance

We believe we have put forward a good faith settlement that is fair and will have far more of a positive impact for the City of Vero Beach We respectfully ask that you exercise your discretion in an act of grace and forgiveness and grant an amendment to this fine and that you work with us to help us stay afloat during these very difficult times

Please let us know if you have any questions we can be reached at (305 )322-5944 We are also prepared to attend the August I 8th City Council meeting and would appreciate the opportunity to speak to the Council and answer any questions

Sincerely

Dr Tony Abbassi and Mrs Lorange Abbassi

From GWP Realty Sent Friday July 31 2020 1043 AM To Falls Monte ltMFallscovborggt Jeffries Jason ltJJeffriescovborggt tabbassi01gmailcom Cc Turner John ltJTurnercovborggt Currey Dave ltDCurreyvbpdorggt Lawson Cindy ltCLawsoncovborggt Subject RE Request for Meeting

Hello Mr Falls As indicated in your email please see Dr Abbassis offer and request to be considered by the City Council We eagerly await your response and the opportunity to address this matter before the City Council on August 18th bull

Best Regards

Rachel Fresco

20801 Biscayne Blvd Aventura Fl33180 T 305-519-3630 T 954-734 2912 F 786 524-0657

From Falls Monte ltMFallscovborggt Sent Wednesday July 22 2020 303 PM To GWP Realty ltrachelgwprealtycomgt Jeffries Jason ltJJeffriescovborggt Cc Turner John ltJTurnercovborggt Currey Dave ltDCurrey)vbpdorggt Lawson Cindy ltCLawsoncovborggt Subject RE Request for Meeting

Ms Fresco The City does not see the need or basis for negotiating the amount due as established by the Code Enforcement Board and the Circuit Court Our obligation is to proceed with collection of the amount due as authorized by law If Dr Abbassi would like to make an offer to be considered by our City Council at its next meeting (August 18th ) we would need said offer by August 4th

Monte K Fans PE City Manager City of Vero Beach mfallscovborg 772-978-4710

ore be subject to public disclosure

2

We are respectfully requesting the imposition of a reasonable adjustment to the fine imposed by the City Council that is consistent with the letter and the spirit of the Florida Statutes and the Florida Constitution We are very reputable individuals who simply never received the Citys notices Had the notices gone directly to our residence there is zero doubt that we would have taken care of the problem that the Property Management company caused We gave them the house to rent and unbeknownst to us the property manager was renting the property in an unauthorized manner

During this whole time we were very busy with our medical practice and we hired the property management company to take care of the rental property and trusted them to do the right thing We are law-abiding citizens with a spotless record (absent this fine) and a very well-respected medical practice that is beloved by our patients who we treat as our family members

As stated earlier this Vero Beach property had a great amount of debt that still has to be paid off

CONCLUSION

In sum we are offering to pay back double the pecuniary gain derived from the offense as contemplated by the Florida Statutes which in this case would be a $150000 settlement In addition I will gladly donate the remainder of the fine via donation of my time to the Treasure Coast Community Health Center in Vero Beach FL I am willing to work and provide 50 hours of medical consultations each year for the next 2 years at the Community Health Center to provide free high quality medical care to the people of Vero Beach FL who lack financial resources to receive this assistance

We believe we have put forward a good faith settlement that is fair and will have far more of a positive impact for the City of Vero Beach We respectfully ask that you exercise your discretion in an act of grace and forgiveness and grant an amendment to this fine and that you work with us to help us stay afloat during these very difficult times

Please let us know if you have any questions we can be reached at (305 )322-5944 We are also prepared to attend the August I 8th City Council meeting and would appreciate the opportunity to speak to the Council and answer any questions

Sincerely

Dr Tony Abbassi and Mrs Lorange Abbassi

From GWP Realty Sent Friday July 31 2020 1043 AM To Falls Monte ltMFallscovborggt Jeffries Jason ltJJeffriescovborggt tabbassi01gmailcom Cc Turner John ltJTurnercovborggt Currey Dave ltDCurreyvbpdorggt Lawson Cindy ltCLawsoncovborggt Subject RE Request for Meeting

Hello Mr Falls As indicated in your email please see Dr Abbassis offer and request to be considered by the City Council We eagerly await your response and the opportunity to address this matter before the City Council on August 18th bull

Best Regards

Rachel Fresco

20801 Biscayne Blvd Aventura Fl33180 T 305-519-3630 T 954-734 2912 F 786 524-0657

From Falls Monte ltMFallscovborggt Sent Wednesday July 22 2020 303 PM To GWP Realty ltrachelgwprealtycomgt Jeffries Jason ltJJeffriescovborggt Cc Turner John ltJTurnercovborggt Currey Dave ltDCurrey)vbpdorggt Lawson Cindy ltCLawsoncovborggt Subject RE Request for Meeting

Ms Fresco The City does not see the need or basis for negotiating the amount due as established by the Code Enforcement Board and the Circuit Court Our obligation is to proceed with collection of the amount due as authorized by law If Dr Abbassi would like to make an offer to be considered by our City Council at its next meeting (August 18th ) we would need said offer by August 4th

Monte K Fans PE City Manager City of Vero Beach mfallscovborg 772-978-4710

ore be subject to public disclosure

2

From GWP Realty Sent Friday July 31 2020 1043 AM To Falls Monte ltMFallscovborggt Jeffries Jason ltJJeffriescovborggt tabbassi01gmailcom Cc Turner John ltJTurnercovborggt Currey Dave ltDCurreyvbpdorggt Lawson Cindy ltCLawsoncovborggt Subject RE Request for Meeting

Hello Mr Falls As indicated in your email please see Dr Abbassis offer and request to be considered by the City Council We eagerly await your response and the opportunity to address this matter before the City Council on August 18th bull

Best Regards

Rachel Fresco

20801 Biscayne Blvd Aventura Fl33180 T 305-519-3630 T 954-734 2912 F 786 524-0657

From Falls Monte ltMFallscovborggt Sent Wednesday July 22 2020 303 PM To GWP Realty ltrachelgwprealtycomgt Jeffries Jason ltJJeffriescovborggt Cc Turner John ltJTurnercovborggt Currey Dave ltDCurrey)vbpdorggt Lawson Cindy ltCLawsoncovborggt Subject RE Request for Meeting

Ms Fresco The City does not see the need or basis for negotiating the amount due as established by the Code Enforcement Board and the Circuit Court Our obligation is to proceed with collection of the amount due as authorized by law If Dr Abbassi would like to make an offer to be considered by our City Council at its next meeting (August 18th ) we would need said offer by August 4th

Monte K Fans PE City Manager City of Vero Beach mfallscovborg 772-978-4710

ore be subject to public disclosure

2

Philo Sherri

From Turner John Sent Thursday August 6 2020 220 PM To Darleneelitetitleverobeachcom Cc Tulkoff Allison Falls Monte Philo Sherri Currey Dave Subject FW Abbssi payoff

Darlene See below for the amount due on the Abbassi lien This will be due as of 818 which is the date the Abbassis will address City Council on the amount due John Turner

From Brost Kelley ltKBrostcovborggt Sent Thursday August 06 2020 202 PM To Turner John ltJTurnercovborggt Cc Tulkoff Allison ltATulkoffcovborggt Subject RE Abbssi payoff

Hi John

Below is the calculated interest as of 8182020 for the CE Lien requested

3766 Ocean Drive Amount owed for the lien= $41102226 Interest= $2954000 Total Due = $44056226

Let me know if you need anything additional Thanks Kelley

From Turner John ltJTurnercovborggt Sent Thursday August 06 2020 112 PM To Brost Kelley ltKBrostcovborggt Cc Tulkoff Allison ltATulkoffcovborggt Subject Abbssi payoff

Good Afternoon Kelly Do you still have the data on the Abbassi lien If so please calculate the payoff as of 818 Thanks for your help jt

1

Burskk Tamm

From Falls Monte Sent Tuesday August 4 2020 918 AM To GWP Realty tabbassi01gmailcom Cc Turner John Bursick Tammy Subject RE Request for Meeting-Please let me know if you received the email

It will be on the agenda I wiil get you details later

Monte Ilt Falls PE City Manager City of Vero Beach mfallscovborg 772-978-4710

From GWP Realty ltrachelgwprealtycomgt Sent Tuesday August 04 2020 916 AM To Falls Monte ltMFallscovborggt tabbassi01gmailcom Cc Turner John ltJTurnercovborggt Bursick Tammy lttbursickcovborggt Subject RE Request for Meeting-Please let me know if you received the email

SECURITY WARNING This message has originated from an EXTERNAL SOURCE Please show caution when clicking links opening attachments or respondin to this email unless ou reco nize the sender and know the content is safe

Hello Mr Falls

I am writing to inquire as to how to make sure this issue is raised during the August 18 2020 city council meeting We would like the opportunity to be heard and for the council to at least come to grips with what has occurred here Please advise

Best Regards

Rachel Fresco

20801 Blscayne Blvd Aventura Fi 33180 T 305-519-3630 T 954-734-2912 F 786-524-0657

1

From Falls Monte ltMFalscovborggt Sent Friday July 31 2020 845 PM To GWP Realty ltrnpoundbfilgyvpreatycomgt Cc Turner John ltJTumercovborggt Bursick Tammy lttbursickcovborggt Subject Re Request for Meeting-Please let me know if you received the email

Yes Received

Sent from my iPhone

On Jul 31 2020 at 439 PM GWP Realty ltrache)gwprealtycomgt wrote

SECURITY WARNING This message has originated from an EXTERNAi SOURCE Please show caution when clicking links openin attachments or respondin to this email unless ou reco nize the sender and know the content is safe

Hello Mr Falls Please let me know if you received the email

Best Regards

Rache Fresco ltimage001jpggt

20801 Biscayne Blvd Aventura Fl 33180 T 305-519-3630 T 954-734-2912 F786-524-0657

from GWP Realty Sent Friday July 31 2020 1043 AM To Falls Monte ltMFalscovborggt Jeffries Jason ltJJeffriescovborggt tabbassi01gmailcom Cc Turner John ltJTurnercovborggt Currey Dave ltDCurreyvbpdorggt Lawson Cindy ltCLawsoncovborggt Subject RE Request for Meeting

Hello Mr Falls As indicated in your email please see Dr Abbassis offer and request to be considered by the City Council We eagerly await your response and the opportunity to address this matter before the City Council on August 18th -

Best Regards

Rachel Fresco ltirnage001jpggt

2

20801 Biscayne Blvd Aventura Fl 33180 T 305-519-3630 T 954-734-2912 F 786-524-0657

From Falls Monte ltMFalscovborggt Sent Wednesday July 22 2020 303 PM To GWP Realty ltrachel)gwpreatvcomgt Jeffries Jason ltJJeffriescovborggt Cc Turner John ltJTurner(covborggt Currey Dave ltDCurreyvbpdorggt Lawson Cindy ltCLawsoncovborggt Subject RE Request for Meeting

Ms Fresco The City does not see the need or basis for negotiating the amount due as established by the Code Enforcement Board and the Circuit Court Our obligation is to proceed with collection of the amount due as authorized by law If Dr Abbassi would like to make an offer to be considered by our City Council at its next meeting (August 18th we would need said offer by August 4th_

Monte K Fas PE City Manager City of Vero Beach mfaiscovborg 772-978-4710

From GWP Realty ltrachelgwprealtycomgt Sent Wednesday July 22 2020 1220 PM To Jeffries Jason ltJJeffriescovborggt Falls Monte ltMFascovborggt Cc Turner John ltJTurner(dlcovborggt Currey Dave ltDCurreyvbpdorggt Subject RE Request for Meeting

SECURITY WARNING This message has originated from an EXTERNAL SOURCE Please show caution when clicking links openin attachments or respondin to this email unless ou reco nize the sender and know the content is safe

Hello Thank you to everyone for your efforts Please if you can advise what was the outcome of the meeting and how we can make this happen it will be greatly appreciated

Best Regards

Rachel Fresco ltirnage001jpggt

20801 Biscayne Blvd Aventura F 33180 T 305-519-3630 T 954-734-2912 F 786-524-0657

3

From Jeffries Jason ltJJeffriescovborggt Sent Wednesday July 22 2020 837 AM To Falls Monte ltMFalscovborggt GWP Realty ltr_achegwprealtycomgt Cc Turner John ltJTurnercovborggt Currey Dave ltDCurreyvbpdorggt Subject RE Request for Meeting

l am meeting with Ken Daige and Tom Ramsey about site plan code issues in his neighborhood at 930 l wlI to wrap it up quickly

Jason H Jeffries ACP Planning and Development Director City of Vero Beach 1053 20th Place Vero Beach Fl 32961 Ph (772) 978-4552

From Falls Monte Sent Wednesday July 22 2020 656 AM To GWP Realty lt_r_acb_filg_wpreatycomgt Jeffries Jason ltJJeffriescovborggt Cc Turner John ltJTurnercovborggt Currey Dave lt0Curreyvbpdorggt Subject RE Request for Meeting

John and Jason have a meeting with Chief Currey at 1000 today if you are available to discuss this Thanks

Monte K Falls PE City Manager City of Vero Beach mfaiscovborg 772-978-4710

From GWP Realty ltrachelgwpreatycomgt Sent Tuesday July 21 2020 750 PM To Falls Monte ltMFalscovborggt Jeffries Jason lt1Jeffrlescovborggt Cc Turner John ltJTumer)covborggt Currey Dave lt0Curreyvbpdorggt Subject RE Request for Meeting

SECURITY WARNING This message has originated from an EXTERNAL SOURCE Please show caution when clicking links openin attachments or respondin to this email unless ou reco nize the sender and know the content is safe

Hello Mr Falls Thank you and Mr Jeffries for your prompt response We Would like to know if there would be a way that the city council could pass a mitigation of the fine in exchange for services that Dr Abbassi could provide for the city of Vero Beach (perhaps community health center consultations)and or COVID-19 consultations We would like to find closure to this case as this has been very traumatic to Dr Abbassi who has already been under unprecedented stress treating COVID-19 cases at South Florida Hospitals We await your response

4

Best Regards

Rachel Fresco ltimage00ljpggt

20801 Biscayne Blvd Aventura F 33180 T 305-519-3630 T 954-734-2912 F 786-524-0657

From Falls Monte ltMFalscovborggt Sent Tuesday July 21 2020 636 PM To Jeffries Jason ltJJeffriescovborggt Cc Turner John ltJTurnercovborggt Currey Dave ltDCurrevvbpdorggt GWP Realty ltrachelcgwprealtycomgt Subject Re Request for Meeting

Jason Thanks

Ms Fresco Please see the response from Jason Jeffries

Sent from my iPhone

On Jul 21 2020 at 532 PM Jeffries Jason ltJJeffriescovborggt wrote

The Abbassi property 3766 Ocean Dr never was heard by City CounciL

The code enforcement board upheld the ien The Abbassis appealed the lien to Circuit Court The court upheld the code enforcement lien The Abbassis waived their right to appeal the code enforcement lien to City Council bv appealing the lien to Circuit Court

Their only recourse is to appeal the Circuit Court decision to the 4 th DCA

Jason H Jeffries ACP Planning and Development Director City of Vero Beach 1053 20th Place Vero Beach FL 32961 Ph (772) 978-4552

From Falls Monte Sent Monday July 20 2020 324 PM To Jeffries Jason ltJJeffriescovborggt Subject FW Request for Meeting

Jason Please let me know when you find the information Thanks

5

Monte IC Fals PE City Manager City of Vero Beach mfaiscovborg 772-978-4710

From GWP Realty ltrachelgwpreatycomgt Sent Monday July 20 2020 233 PM To Falls Monte ltMFals)covborggt Cc Turner John lt1Tumercovborggt Currey Dave ltDCurreyvbpdorggt Subject RE Request for Meeting

SECURITY WARNING This message has originated from an EXTERNAL SOURCE Please show caution when clicking links opening attachments or responding to this email unless you recognize the sender and know the content is safe

Good Afternoon Mr Falls

Just wanted to touch base to see if you had a chance to speak with the City Attorney and Chief of Police We are eagerly awaiting your response

Best Regards

Rachel Fresco ltimage001jpggt

20801 Biscayne Blvd Aventura Fl33180 T 305-519-3630 T 954-734-2912 F 786-524-0657

From GWP Realty Sent Thursday July 16 2020 1045 AM To Falls Monte ltMFalscovborggt Cc Turner John lt1Tumercovborggt Currey Dave ltDCurreyvbpdorggt Subject Re Request for Meeting

Thank you so much Looking forward to meeting with you soon As time is of the essence your prompt response will be greatly appreciated

Best Regards

6

Rache Fresco

20801 Bvd

fl 33180

T 305-519-3630

T 954-734-2912

F 786-524-0657

On Jul 16 2020 at 636 AM Falls Monte ltMFallscovborggt wrote

l wl discuss this with the City Attorney and Police Chief (Code Enforcement) and get back to you

Monte llt Fas PE City Manager City of Vero Beach mfalscovborg 772-978-4710

From GWP Realty ltrache~gt Sent Wednesday July 15 2020 825 PM To City Manager ltCityManagercovborggt Subject Request for Meeting

SECURITY WARNING This message has originated from an EXTERNAL SOURCE Please show caution when clicking links opening attachments or responding to this email unless you recognize the sender and know the content is safe

Dear City Manager Falls

Hope this message finds you well I am writing on behalf of my friend Dr Tony Abbassi a Vero Beach Property Owner who was unfortunately mixed up unbeknownst to him in a city fine issue because his property manager was not aware of the citys rental policy

7

Because Dr Abbassi has been working 247 fighting COVID-19 and saving patients in Miami he has not been able to reach out to you However I was wondering if we could please meet with you next week to discuss a reasonable accommodation to this quite unreasonable fine

Dr Abbassi is a pillar of the community and has never turned away from anyone in their time of need Hopefully the City of Vero Beach will do the same during these difficult times

I look forward to hearing from you to make this happen

Best Regards

Rachel Fresco ltimage001jpggt

20801 Biscayne Blvd Aventura fl 33180 T 305-519-3630 T 954-734-2912 F786-524-0657

Please Note ronda has a very broad Public Records Lav_ Most 11Vriiten cornrnunfcations to or fron1 State and Local Officials and agencies nsgarding State or Local f)usiness are pubfc records available to the public and rnedia upon request Your ernail carnrnunications including your email adcfress may therefore Je suJject to public cfisclosure

Please Note Ffoticla has a vey broad PuiJfic Records Lavv tVosf vvritten cornrnunications to or frorn State ancf Local Officials and auencies regarding State or Local business are public records avoifabfe to the pubfif and media upon request Your ernai cornrnunicafions including your ernaif adt1ress 1nay therefore be sufJject to pubfie disclosure_

Please Note Florida has s very broad rgtuJlfc Records Law Vlost Vitten cornrnunications to or fron1 State and Local Officials and agencies regarcling State or Local business are puJJc records available to the public and n1ecfiamp upon request Your en1aif conrn1unfcations including your ernaif address rnay therefore be sul1ject to public disclosure

Please Note FOk1a has e vew broad Public Records Law Wost written communications to or from State and Local omctes and agencies regarding State or Loca bush1ess are public records avalfablo to the public and rnedia upon request Your ernaiJ con1n1unicatfons jncfuding your einaii aodress1 nay therefore be subject to puhic discfosure

ltDr Abbassi-3766 Ocean Drive Vero Beach Propertypdfgt ltGlobal Retreatspdfgt

8

Please Note Florida has a vey broad Puliic Records Lat-v lVlost tNritten cornrnunications to or frorn State ancf Local Officials end agencies regarding State or Loco business an public records available to the public and tnedia upon request Your e1nail cornrnunicaffons including your email adcfress may theretcire he subject to public disclosure

9

AMOUNT DUE FOR CODE ENFORCEMENT LIENS ON 3766 OCEAN DRIVE

TONY AND FLORANGEL ABBASSI

reg Original Fine reg Cost of Enforcement e Cost of Enforcement bull Cost of Continuing FinesPenalties e Cost of Recording Orders bull Cost for City Attorney for Release bull Cost to Record Release of Lien

Sub-Total

Interest at Legal Rate

Total Amount Due 81820

$50000 $44891 $244285 $40750000 $3700 $7500 $1850

$41102226

$2954000

$44056226

Decision of CEB was appealed to Circuit Court which affirmed CEBs decision on 63020

Please Note Florida has a vey broad Puliic Records Lat-v lVlost tNritten cornrnunications to or frorn State ancf Local Officials end agencies regarding State or Loco business an public records available to the public and tnedia upon request Your e1nail cornrnunicaffons including your email adcfress may theretcire he subject to public disclosure

9

AMOUNT DUE FOR CODE ENFORCEMENT LIENS ON 3766 OCEAN DRIVE

TONY AND FLORANGEL ABBASSI

reg Original Fine reg Cost of Enforcement e Cost of Enforcement bull Cost of Continuing FinesPenalties e Cost of Recording Orders bull Cost for City Attorney for Release bull Cost to Record Release of Lien

Sub-Total

Interest at Legal Rate

Total Amount Due 81820

$50000 $44891 $244285 $40750000 $3700 $7500 $1850

$41102226

$2954000

$44056226

Decision of CEB was appealed to Circuit Court which affirmed CEBs decision on 63020

AMOUNT DUE FOR CODE ENFORCEMENT LIENS ON 3766 OCEAN DRIVE

TONY AND FLORANGEL ABBASSI

reg Original Fine reg Cost of Enforcement e Cost of Enforcement bull Cost of Continuing FinesPenalties e Cost of Recording Orders bull Cost for City Attorney for Release bull Cost to Record Release of Lien

Sub-Total

Interest at Legal Rate

Total Amount Due 81820

$50000 $44891 $244285 $40750000 $3700 $7500 $1850

$41102226

$2954000

$44056226

Decision of CEB was appealed to Circuit Court which affirmed CEBs decision on 63020

SUMMARY AND TIMEUNE FOR 3766 OCEAN DRIVE

The City of Vero Beach has a long standing ordinance prohibiting transient rentals in a residential zone Transient being defined as a period of less than 30 days Violations of the ordinance incurs a $50000 civil penalty Property has been for sale since March 2015 with Doris (Mangeri) Salazar 3766 Ocean Drive has been advertised on different vacation rental websites since 2013 listings for the home show Randy Rendon Global Retreats as the host for the property Randy Rendon has been the Agent for Global Retreats since 2015 Ms Salazar and Mr Rendon have multiple companies together listings for the property had three (3) night minimum most of the time it was advertised

Rental rates

March 2015 $ 900 night

March 2016 $ 529 night

January-April 2017 $1200 night

August 2017 $ 742 night

September 2017 $ 850 night

November 2017 $ 1000 night

January- March 2018 $ 1250 night

August 2018 $ 796 night

September 2018 $ 650 night

November 2018 $ 1190 night

January- March 2019 $ 1000 night

April 2019 $1200 night

222015 Warning citation issued for operating a guest house and transient quarters in a residential zone

4172015 Citation issued for operating guest house and transient quarters in a residential zone after interview with the tenants

5132015 Code Enforcement Board issues Notice of Assessment to correct the violation and pay civil penalties

5212015 Telephone call with Mrs Abbassi and her Broker Randy Rendon stating they only do monthly rentals and they cannot help if some other company rents the property or how it is advertised on AirBnb Advised them of the City Ordinance regarding rentals for a period of 30 days or more and they stated they knew our Code I advised they could pay or appeal the citation

Per their request a copy of Citation was sent to Randy Rendon at 1211 Hardee Road Coral Gables Fl 33146

Follow up check on rental listing and was changed to 28 day minimum $12 720 month

6102015 Appeal of Notice of Assessment to Code Enforcement Board Property owners did not attend and were represented by legal counsel Violation had been corrected so Board issued order to pay civil penalty and costs

172015 Payment received for civil penalty and costs

3182016 Advertised on Vacation Rental by Owner $529night with 3 night minimum

2102017 Citation issued for operating guest house and transient quarters in a residential zone after interview with the tenant Tenant advised they rented for 1 week and wanted to extend their stay but were unable to do so due another tenant coming

4122017 Code Enforcement Board hearing and property owner did not attend Board issues Order to correct the violation and pay civil penalties

892018 Citation issued for operating guest house and transient quarters in a residential zone Tenants advised they rented girls long weekend

8242018 Telephone call with Randy who identified himself as property owners nephew regarding Citation posted at the property Randy inquired how to keep this from coming up Advised of City Ordinance regarding rentals for a period of 30 days or more Advised he could pay or appeal the Citation

9122018 Code Enforcement Board hearing - property owner did not attend Board issues Order to correct the violation and pay civil penalties

592019 Property sold and going to closing After several telephone calls with Title Company advertising of house as short term rental were removed

6122019 Cases come before the Code Enforcement Board to find property in compliance and stop continuing penalties

6252019 Property sold for $2450000

Case 17-CE-7330 Code Enforcement Board finds violation corrected as of 592019 and issues Order to pay $407500 and costs Case appealed to Circuit Court and Court affirms case in favor of the City of Vero Beach

Case 18-CE-8775 Code Enforcement Board finds violation corrected as of 592019 reduces civil penalties of $135000 by 75 and issues order to pay $3425000

8122019 Payment received for Case 18-CE-8775

Summary

Dr and Mrs Abbassi have stated they did not receive notices at their residence Certified Citations were sent to the address of record on the Indian River County Property Appraiser and posted at the local house The address on the Property Appraiser is the same address annual property taxes were sent by mail and the taxes were always paid timely

The home could have been rented for the 30 days or more as allowed by Vero Beach Ordinance and the daily fine would have ceased The property did not come into compliance until it was sold

Dates and vehicle turnover summaries attached for 2017 2018 and 2019

3182016 Advertised on Vacation Rental by Owner $529night with 3 night minimum

2102017 Citation issued for operating guest house and transient quarters in a residential zone after interview with the tenant Tenant advised they rented for 1 week and wanted to extend their stay but were unable to do so due another tenant coming

4122017 Code Enforcement Board hearing and property owner did not attend Board issues Order to correct the violation and pay civil penalties

892018 Citation issued for operating guest house and transient quarters in a residential zone Tenants advised they rented girls long weekend

8242018 Telephone call with Randy who identified himself as property owners nephew regarding Citation posted at the property Randy inquired how to keep this from coming up Advised of City Ordinance regarding rentals for a period of 30 days or more Advised he could pay or appeal the Citation

9122018 Code Enforcement Board hearing - property owner did not attend Board issues Order to correct the violation and pay civil penalties

592019 Property sold and going to closing After several telephone calls with Title Company advertising of house as short term rental were removed

6122019 Cases come before the Code Enforcement Board to find property in compliance and stop continuing penalties

6252019 Property sold for $2450000

Case 17-CE-7330 Code Enforcement Board finds violation corrected as of 592019 and issues Order to pay $407500 and costs Case appealed to Circuit Court and Court affirms case in favor of the City of Vero Beach

Case 18-CE-8775 Code Enforcement Board finds violation corrected as of 592019 reduces civil penalties of $135000 by 75 and issues order to pay $3425000

8122019 Payment received for Case 18-CE-8775

Summary

Dr and Mrs Abbassi have stated they did not receive notices at their residence Certified Citations were sent to the address of record on the Indian River County Property Appraiser and posted at the local house The address on the Property Appraiser is the same address annual property taxes were sent by mail and the taxes were always paid timely

The home could have been rented for the 30 days or more as allowed by Vero Beach Ordinance and the daily fine would have ceased The property did not come into compliance until it was sold

Dates and vehicle turnover summaries attached for 2017 2018 and 2019

2017 Vehicle Turnover Summary

February 111 Van 29-213 111 214 FL BBQ D31 bull 217-218 NH Truck 282 7154

NJ Volvo 111 220-221 Truck

FLATET07 ltI) 223-225 Chevy SUV

Dark SUV

March 111 32-329 BMW - SIXT Rent a Car LLC

BMW - PV Holding Corp

April 111 45-46 Ford-Suv EAN Holdings LLC bull 413 IL Q3 l 0742 PV Holding Corp 111 418-419 FL GVZ G80 PV Holding Corp

May bull 516 FL DZZJ42 Rental bull 522-523 Truck 324 7PL

Truck 113 ISA SUV PH2 4OL Dealer

bull 525-527 St Petersburg FL 111 529 Dark SUV

July 111 78-710 Camper FL HZM Q35 RV LLC

Truck FL GEK L93 Miami FL 111 712-713 Van GYK T43 Hillsborough FL 111 716-718 Truck FL ETE A99 Weston FL

SUV CCG Y70 Weston FL bull 719

FL DFE L65 Hialeah FL 111 721-724 FL ETY J83 Deltona FL

FL EZA U57 Miami FL FL 750 LGW EAN Holdings LLC

Ill 728-729 FL CZW F63 Broward FL

111

August o 82-83 Dark SUV 824 Small car e 825 FL BWE S75 EAN Holdings LLC

September bull 91 Van

White BMW e 911 White car

Ford SUV 926 Dodge N961GA Vero Beach

October No cars observed outside of the garage

November 118-119 Balloons observed in the house - no cars observed outside of the garage bull 1120 FL ATE T07 Vero Beach bull 1127-11-29 White car

December bull 1211 3 people seen walking down the driveway- no cars observed outside of the

middotmiddotmiddotmiddotgarage o 1227-132018 CTLC92 SIXT Rent a car

2018 Vehicle Turnover Summary

January bull 1227-13 CTL C82 SIXT Rent a car bull 14 - 130 No cars observed outside of garage

February middotft middot 27 Car on drive and a golfer bull 28 Dark car

Dark SUV White car

bull 212 FL CAQG93 Vero Beach FL JBM F48 BAN Holdings

bull 216 FL CTQT49 Hertz rental MD651 M432 FL JBM F48 BAN Holdings

bull 222 FL BWG T30 BAN HOLDINGS

March bull 36-312 FL HLG B23 Hertz rental

VA VMC6349 FL GHlJ E73 SIXT Rent a car

bull 313-319 IA GBJ 149 reg 323-42 IL Ql9 8559

IL Boat trailer

April bull 42-48 FL JLJ B79 SIXT Rent a car

FLDQCN29

May bull 57 White truck 517 Garage open bull 5122 Chevrolet SUV

June bull 65 Van bull 68 Car bull 614-615 Truck FL EEX7 Orlando FL

July ft 75-723 FL 452 QDD Vulin Coral Springs FL

FLENQX99 FLHHXS0

August bull 821-829 White van

September _ bull 924 Blue car

October 111 105-108 White SUV

November bull 119 White van

December bull 1228 Black vehicle

2019 Vehicle Turnover Summary January

0 17-115 Van backed in copy 122-218 FL BPL Q47 EAN Holdings

PA JOF705J Dealer

March bull 38-318 Van backed in o 327-329 OH HOX 1072

Black SUV

April bull 43-44 Maroon car backed in garage

Philo Sherri

From Turner John Sent Thursday August 6 2020 220 PM To Darleneelitetitleverobeachcom Cc Tulkoff Allison Falls Monte Philo Sherri Currey Dave Subject FW Abbssi payoff

on the 2rnount due John Turner

interest= Tota Due=

be as of is date the

From Brost Kelley ltKBrostcovborggt Sent Thursday August 06 2020 202 PM To Turner John ltJTumercovborggt Cc Tulkoff Allison ltATulkoffcovborggt Subject RE Abbssi payoff

if vou need additionaL

from Turner John Sent Thursday August 06 2020 112 PM To Brost Kelley Cc Tukoff Allison Subject Abbssi payoff

Good Afternoon Kelly Do you still have the data on the Abbassi lien f so please calculate the payoff as of 818 Thanks for your help jt

1

111

August o 82-83 Dark SUV 824 Small car e 825 FL BWE S75 EAN Holdings LLC

September bull 91 Van

White BMW e 911 White car

Ford SUV 926 Dodge N961GA Vero Beach

October No cars observed outside of the garage

November 118-119 Balloons observed in the house - no cars observed outside of the garage bull 1120 FL ATE T07 Vero Beach bull 1127-11-29 White car

December bull 1211 3 people seen walking down the driveway- no cars observed outside of the

middotmiddotmiddotmiddotgarage o 1227-132018 CTLC92 SIXT Rent a car

2018 Vehicle Turnover Summary

January bull 1227-13 CTL C82 SIXT Rent a car bull 14 - 130 No cars observed outside of garage

February middotft middot 27 Car on drive and a golfer bull 28 Dark car

Dark SUV White car

bull 212 FL CAQG93 Vero Beach FL JBM F48 BAN Holdings

bull 216 FL CTQT49 Hertz rental MD651 M432 FL JBM F48 BAN Holdings

bull 222 FL BWG T30 BAN HOLDINGS

March bull 36-312 FL HLG B23 Hertz rental

VA VMC6349 FL GHlJ E73 SIXT Rent a car

bull 313-319 IA GBJ 149 reg 323-42 IL Ql9 8559

IL Boat trailer

April bull 42-48 FL JLJ B79 SIXT Rent a car

FLDQCN29

May bull 57 White truck 517 Garage open bull 5122 Chevrolet SUV

June bull 65 Van bull 68 Car bull 614-615 Truck FL EEX7 Orlando FL

July ft 75-723 FL 452 QDD Vulin Coral Springs FL

FLENQX99 FLHHXS0

August bull 821-829 White van

September _ bull 924 Blue car

October 111 105-108 White SUV

November bull 119 White van

December bull 1228 Black vehicle

2019 Vehicle Turnover Summary January

0 17-115 Van backed in copy 122-218 FL BPL Q47 EAN Holdings

PA JOF705J Dealer

March bull 38-318 Van backed in o 327-329 OH HOX 1072

Black SUV

April bull 43-44 Maroon car backed in garage

Philo Sherri

From Turner John Sent Thursday August 6 2020 220 PM To Darleneelitetitleverobeachcom Cc Tulkoff Allison Falls Monte Philo Sherri Currey Dave Subject FW Abbssi payoff

on the 2rnount due John Turner

interest= Tota Due=

be as of is date the

From Brost Kelley ltKBrostcovborggt Sent Thursday August 06 2020 202 PM To Turner John ltJTumercovborggt Cc Tulkoff Allison ltATulkoffcovborggt Subject RE Abbssi payoff

if vou need additionaL

from Turner John Sent Thursday August 06 2020 112 PM To Brost Kelley Cc Tukoff Allison Subject Abbssi payoff

Good Afternoon Kelly Do you still have the data on the Abbassi lien f so please calculate the payoff as of 818 Thanks for your help jt

1

2018 Vehicle Turnover Summary

January bull 1227-13 CTL C82 SIXT Rent a car bull 14 - 130 No cars observed outside of garage

February middotft middot 27 Car on drive and a golfer bull 28 Dark car

Dark SUV White car

bull 212 FL CAQG93 Vero Beach FL JBM F48 BAN Holdings

bull 216 FL CTQT49 Hertz rental MD651 M432 FL JBM F48 BAN Holdings

bull 222 FL BWG T30 BAN HOLDINGS

March bull 36-312 FL HLG B23 Hertz rental

VA VMC6349 FL GHlJ E73 SIXT Rent a car

bull 313-319 IA GBJ 149 reg 323-42 IL Ql9 8559

IL Boat trailer

April bull 42-48 FL JLJ B79 SIXT Rent a car

FLDQCN29

May bull 57 White truck 517 Garage open bull 5122 Chevrolet SUV

June bull 65 Van bull 68 Car bull 614-615 Truck FL EEX7 Orlando FL

July ft 75-723 FL 452 QDD Vulin Coral Springs FL

FLENQX99 FLHHXS0

August bull 821-829 White van

September _ bull 924 Blue car

October 111 105-108 White SUV

November bull 119 White van

December bull 1228 Black vehicle

2019 Vehicle Turnover Summary January

0 17-115 Van backed in copy 122-218 FL BPL Q47 EAN Holdings

PA JOF705J Dealer

March bull 38-318 Van backed in o 327-329 OH HOX 1072

Black SUV

April bull 43-44 Maroon car backed in garage

Philo Sherri

From Turner John Sent Thursday August 6 2020 220 PM To Darleneelitetitleverobeachcom Cc Tulkoff Allison Falls Monte Philo Sherri Currey Dave Subject FW Abbssi payoff

on the 2rnount due John Turner

interest= Tota Due=

be as of is date the

From Brost Kelley ltKBrostcovborggt Sent Thursday August 06 2020 202 PM To Turner John ltJTumercovborggt Cc Tulkoff Allison ltATulkoffcovborggt Subject RE Abbssi payoff

if vou need additionaL

from Turner John Sent Thursday August 06 2020 112 PM To Brost Kelley Cc Tukoff Allison Subject Abbssi payoff

Good Afternoon Kelly Do you still have the data on the Abbassi lien f so please calculate the payoff as of 818 Thanks for your help jt

1

August bull 821-829 White van

September _ bull 924 Blue car

October 111 105-108 White SUV

November bull 119 White van

December bull 1228 Black vehicle

2019 Vehicle Turnover Summary January

0 17-115 Van backed in copy 122-218 FL BPL Q47 EAN Holdings

PA JOF705J Dealer

March bull 38-318 Van backed in o 327-329 OH HOX 1072

Black SUV

April bull 43-44 Maroon car backed in garage

Philo Sherri

From Turner John Sent Thursday August 6 2020 220 PM To Darleneelitetitleverobeachcom Cc Tulkoff Allison Falls Monte Philo Sherri Currey Dave Subject FW Abbssi payoff

on the 2rnount due John Turner

interest= Tota Due=

be as of is date the

From Brost Kelley ltKBrostcovborggt Sent Thursday August 06 2020 202 PM To Turner John ltJTumercovborggt Cc Tulkoff Allison ltATulkoffcovborggt Subject RE Abbssi payoff

if vou need additionaL

from Turner John Sent Thursday August 06 2020 112 PM To Brost Kelley Cc Tukoff Allison Subject Abbssi payoff

Good Afternoon Kelly Do you still have the data on the Abbassi lien f so please calculate the payoff as of 818 Thanks for your help jt

1

2019 Vehicle Turnover Summary January

0 17-115 Van backed in copy 122-218 FL BPL Q47 EAN Holdings

PA JOF705J Dealer

March bull 38-318 Van backed in o 327-329 OH HOX 1072

Black SUV

April bull 43-44 Maroon car backed in garage

Philo Sherri

From Turner John Sent Thursday August 6 2020 220 PM To Darleneelitetitleverobeachcom Cc Tulkoff Allison Falls Monte Philo Sherri Currey Dave Subject FW Abbssi payoff

on the 2rnount due John Turner

interest= Tota Due=

be as of is date the

From Brost Kelley ltKBrostcovborggt Sent Thursday August 06 2020 202 PM To Turner John ltJTumercovborggt Cc Tulkoff Allison ltATulkoffcovborggt Subject RE Abbssi payoff

if vou need additionaL

from Turner John Sent Thursday August 06 2020 112 PM To Brost Kelley Cc Tukoff Allison Subject Abbssi payoff

Good Afternoon Kelly Do you still have the data on the Abbassi lien f so please calculate the payoff as of 818 Thanks for your help jt

1

Philo Sherri

From Turner John Sent Thursday August 6 2020 220 PM To Darleneelitetitleverobeachcom Cc Tulkoff Allison Falls Monte Philo Sherri Currey Dave Subject FW Abbssi payoff

on the 2rnount due John Turner

interest= Tota Due=

be as of is date the

From Brost Kelley ltKBrostcovborggt Sent Thursday August 06 2020 202 PM To Turner John ltJTumercovborggt Cc Tulkoff Allison ltATulkoffcovborggt Subject RE Abbssi payoff

if vou need additionaL

from Turner John Sent Thursday August 06 2020 112 PM To Brost Kelley Cc Tukoff Allison Subject Abbssi payoff

Good Afternoon Kelly Do you still have the data on the Abbassi lien f so please calculate the payoff as of 818 Thanks for your help jt

1

-----------

VERO BEACH POLICE DEPARTMENT CODE ENFORCEMENT DNISION CODE ENFORCEMENT CITATION

1055 20th Street Vero Beach FL 32960 No 1034M 17-CE-7330

STATE OF FLORIDA COUNTY OF INDIAN RIVER CITY OF VERO BEACH

In the name of the City of Vero Beach Florida The undersigned officer certifies that heshe has just and reasonable grounds to believe and does believe that on February 10 2017 at na

Name Abbassi Tony and Lorange 1643 Brickell Ave Unit 2403

of Miami FL 33129

at (violation address) 3766 Ocean Drive in the City of Vero Beach Florida committed the following civil offense Operating a guest house and transient quarters in a residential zone

Violation of code provision(s) 60116006 6102 6103

Facts constituting violation Based on best available information subject property is being utilized for transient rentals guesthouses for compensation for periods of less than 30 days All rental activities of this nature and the advertising of such activities must cease immediately Future violations are subject to further Code Enforcement actions CIVIL PENALTY $50000 PAY BY DATE 02272017 REPEAT VIOLATION

CORRECTION REQUIRED BY 02122017 This is a correctable violation and must be corrected by the date specified Each day that the violation remains uncorrected after the date specified is a separate violation and additional civil penalties and costs may be assessed against you without issuance of additional citations You must contact the issuing officer and request re-inspection once the violation is corrected or if you need additional time to correct the violation If you do not correct the violation by the date specified the City may also take action to correct the violation and assess the costs of correction plus administrative fees as a lien against the property on which the violation was corrected in addition to any lien for civil penalties or costs

Issued by Sanderson Date Issued 02102017 Department VBPD Code Enforcement Telephone 7729784561

RIGHT TO HEARING OR TO PAY REDUCED PENALTY You must either file a written request for a hearing to contest this citation OR pay the reduced civil penalty specified above at City Clerks Office City Hall 1053 20th Place Vero Beach Florida 32960 WRITTEN REQUEST FOR A HEARING MUST BE RECEIVED WITHIN TEN (10) DAYS (excluding Saturdays Sundays and legal holidays) OR YOUR RIGHT TO A HEARING IS WAIVED AND DEEMED YOUR ADMISSION OF THE VIOLATION Make checks payable to City of Vero Beach Do not mail cash If correction of the vioiation is required above the timely fiiing of a request for a hearing will toll the accnal of continuing violation

-----penalties pending outcome of the hearing Your right to pay the reduced penalty specified above is waived if you elect to contest the citation and if after the hearing you are found to be responsible for the violation a civil penalty of up to $500 ($1000 for contracting violations) may be assessed against you for each day of violation plus administrative and enforcement costs

Your signature below acknowledges receipt of a copy of this citation and is NOT an admission of the violation Willful refusal to sign and accept this citation is a misdemeanor criminal offense punishable as provided by law

Date Signature of Individual

CLERK COPY - 17-000146 Certified Mail Receipt 70160191000016546497

BEFORETHECODEENFORCEMENTBOARD OF THE CITY OF VERO BEACH FLORIDA

CITY OF VERO BEACH POLICE DEPARTMENT

VS

Tony and Lorangel Abassi Case Number 17-CE-7330 Violators

AFFIDAVIT OF COSTS STATE OF FLORIDA COUNTY OF INDIAN RIVER

I Melody Sanderson_____ being first duly sworn upon personal knowledge and information depose and state that I am a code enforcement or police officer for the City of Vero Beach Florida and I have personal knowledge of and certify that the City of Vero Beach has incurred the following administrative and prosecution costs in investigation enforcement testing or monitoring relating to the above-styled code enforcement case against the named violator and that the City ofVero Beach is entitled to recovery of said fees and costs from the violator pursuant to the code enforcement ordinance

Officer MS

Activity Date Time Rate Total hours 21017-412171336hrs $ 3311

Amount $44235

MS Complaint Intake me MS Initial Investigation inc MS Initial inspection inc MS Violator conference na MS Telephone conference na MS Hearing attendance inc MS Notice ofviolation preparation inc MS Notice ofhearing preparation inc MS Photoexhibit preparation inc MS Re-inspection inc

Additional Costs and Supplies na Postage $656 Notices (mailed and posted) me Long Distance Telephone na Photographs inc Vehicle Mileage na

Total Costs $ 44891

Melody Sanderson Affiant Officer

Page 1 of2

CUsersmsandersonVBPDDesktopletters and formsAffidavitsAffidavit Costs feb 08docx REVISED 2009docx

Before me the undersigned authority personally appeared the Affiant Melody Sanderson who was duly sworn and who states that heshe has read the foregoing Affidavit of Costs and that the contents are true and correct

r Sworn to and subscribed before me this ~ayof ~ 20fl_ by Melody

Sanderson who is personally known to me OR __lL_ produced ____________ as identification

Jmf~~ NOTAAYPUBUC STATE OF FLORIDA Cfflri00022293 Expllfi 6182019

Page 2 of2

CUsersmsandersortVBPDDesktopletters and formsAffidavitsAffidavit Costs feb 08docx REVISED 2009docx

BEFORE THE CODE ENFORCEMENT BOARD OF THE CITY OF VERO BEACH FLORIDA

CITY OF VERO BEACH

vs

Abbassi Case Number 17-CE-7330 Violator

AFFIDAVIT OF COSTS STATE OF FLORIDA COUNTY OF INDIAN RIVER

I _Melody Sanderson being first duly sworn upon personal knowledge and information depose and state that I am a code enforcement or police officer for the City of Vero Beach Florida and I have personal knowledge of and certify that the City of Vero Beach has incurred the following administrative and prosecution costs in investigation enforcement testing or monitoring relating to the above-styled code enforcement case against the named violator and that the City ofVero Beach is entitled to recovery of said fees and costs from the violator pursuant to the code enforcement ordinance

Officer Activity Date Time Rate Amount $244285 MS Total hours 41317-61219 7378 $ 3311

MS Complaint Intake inc MS Initial Investigation inc MS Initial inspection inc MS Violator conference na MS Telephone conference na MS Hearing attendance inc MS Notice of violation preparation inc MS Notice ofhearing preparation inc MS Photoexhibit preparation inc MS Re-inspection inc

Additional Costs and Supplies na Postage na Notices (mailed and posted) inc T-ong nisfancP Telephone na Photographs inc Vehicle Mileage na

Total Costs $244285 1_~-~2-Vt

Melody Sanderson Affiant Officer

Before me the undersigned authority personally appeared the Affiant Melody Sanderson who was duly sworn and who states that heshe has read the foregoing Affidavit of Costs and that the contents are true and con-ect

Page 1 of2

CUsersmsancersonVBPDDesktopletters and fom1sAffidavisCosts 2018docx

l )Sworn to and subscribeg-bttlcrr~ me this

--7 day of JUtne 20_i_l by Melody

~ I -~--=~~----SanderSOfl who is personatfy knofff to me OR -- produced as identification I(__--

Page 2 of2

CUsersmsamlersonVBPDDesktopletters and formsAffidavitsCosts 2018docx

RECORDED IN THE PUBLIC RECORDS OF JEFFREY R SMITH CLERK OF COURT INDIAN RIVER COUNTY FL BK 3049 PG 2081 Page 1of28182017 121 PM

BEFORE THE CODE ENFORCEMENT BOARD OF THE CITY OF VERO BEACH FLORIDA

1053 20TH PLACE VERO BEACH FLORIDA 32960

CITY OF VERO BEACH CASE NO 17-CE-7330

VS CITATION NO 1034M

TONY AND LORANGEL ABBASSI 1643 Brickell Avenue Unit 2403 Miami Florida 33129

AMENDED ORDER FINDING VIOLATION DIRECTING CORRECTION AND PAYMENT OF CIVIL PENALTY AND COSTS AND IMPOSING CONTINUING

PENALTIES

VIOLATION City of Vero Beach Code sections 6011 6006 6102 6103 - operating a guest house and transient quarters in a residential zone LOCATION 3766 Ocean Drive Vero Beach Florida 32963

The above-styled case having come before the Code Enforcement Board of the City of Vero Beach (Board) on the 1ih day of April 2017 on request of the Code Officer for a Board Order Finding Violation and the Board having heard testimony of the Code Enforcement Officer and argument from the attorney for the City of Vero Beach and the violator regarding the violation and having reviewed the record in this action on motion made and approved found that

1 The citation and notice ofhearing in this case were served as provided by law

2 The violator did not appeal issuance of the citation in this case within the time allowed by law and thereby waived the right to a hearing before the Board to contest the issuance of the citation which waiver of hearing is deemed an admission of the violation specified in the citation The civil penalty in the amount of $50000 has not been paid

3 The City has requested enforcement costs in the amount of $44891 be assessed The City is entitled pursuant to law to recover all costs of recording the Boards orders in the public records and for satisfying and recording releases of the resulting liens upon payment

4 This Order replaces and supersedes the Order dated May 1 2017 recorded at Book 3029 Page 1596 in the Official Records of Indian River County due to a scriveners error in the recorded m~ - -

IT IS THEREFORE ORDERED AND ADJUDGED BY THE BOARD THAT

The violator is deemed to have committed the violation as specified above and on the citation There is hereby imposed the civil penalty of $50000 along with enforcement costs in the amount of $44391which shall be paid to the City Clerk within thirty (30) days from the date of this Order together with all costs incurred by the City for recording the Boards order in the public records and for

Page 1 of2

-iu~JHA5 uuu HAvrnmg nacase UI me resumng llens upon payment The violator shall correct the vi0lntio11 within 10 days from the Board order or a continuing civil penalty of $500 per day shall commence until the property is brought into compliance

DONE AND ORDERED at Vero Beach Indian River County Florida this 1~ day of ampvFt- 2011

ATTEST ctORCEME

Christophe

As Board Clerk Vice Chairman

[Seal]

Approved as to form and legal sufficiency

BY - ttCdeg DATE ftfrac12(ffrac12cf f ~1ampb~i

Kira C Honse --As Board Attorney

IMPORTANT INFORMATION

Payment of Civil Penalties and Costs You must contact the City Clerks office at 772-978-4700 for the total amount of civil penalties enforcement costs recording and other costs required to satisfy this order and lien Civil penalties and costs may be paid in person at the City Clerks office located in City Hall 1053 20th Place Vero Beach Florida 32960 Monday through Friday between 830 am and 500 pm or by mailing a check or money order to said address payable to City of Vero Beach Do not mail cash

Repeat Violation Repeat violation of the same Code provision by the violator even if committed at a different location can result in the issuance of a code enforcement citation and assessment of increased civil penalties for the repeat offense

Notice ofRight to Appeal Board Decision An aggrieved party may appeal the Boards order to the Circuit Court in Indian River County Florida A written notice of appeal together with a copy of the order appealed must be filed with the Clerk of the Code Enforcement Board and with the Clerk of the Circuit Court together with the applicable court filing fees within thirty (30) days after the date of this order or the right to appeal is waived An appeal is limited to appellate review of the record of the proceedings created before the Code Enforcement Board Ref FS 26012(1) Florida Rules of Appellate Procedure 9030(c)(l)(C) 91 I0(c)

Page 2 of2

JEFFREY R SMITH CLlKK Ur cuurlt I tNOIAN RIVER COUNTY FL BK 3228 PG 426 Page 1of2852019129 PM

BEFORETHECODEENFORCEMENTBOARD OF THE CITY OF VERO BEACH FLORIDA

I 053 20TH PLACE VERO BEACH FLORIDA 32960

CITY OF VERO BEACH CASE NO17-CE-7330

vs CITATION NO 1034M

TONY ABBASSI AND FLORANGEL ABBASSI 7171 Old Cutler Road Coral Gables Florida 33143

ORDER FINDING CORRECTION OF VIOLATION CEASING CONTINUING PENALTIES AND TO PAY PENALTIES AND COSTS

VIOLATION City of Vero Beach Code sections 6006 6011 6102 6103 - Operating a guest house and transient quarters in a residential zone LOCATION 3766 Ocean Drive Vero Beach Florida 32963

The above-styled case having come before the Code Enforcement Board of the City of Vero Beach (Board) on the 12th day of June 2019 on request of the Code Officer for a Board Order and the Board having heard testimony of the Code Officer and of the renting agent of the property and having reviewed the record in this action on motion made and approved found that

1 The notice ofhearing in this case was served as provided by law

2 The property was found to be in compliance on May 9 2019 by the Code Officer and continuing civil penalties accrued from February 13 2017 through May 08 2019 (day prior to finding properjy in compliance) a total of 815 days at $50000 per day for an amount due of $40750000

3 There is a cost of enforcement in the amount of $44891 as listed in the previous Board Order Finding Violation Directing Correction and Payment of Civil e_enalties and Costs and Imposing Continuing Penalties (21017 -41217)

4 There are additional costs of enforcement in the amount of $244285 ( 41317 - 61219) The initial civil penalty of $50000 remains unpaid

5 The City is entitled pursuant to law to recover all costs of recording the Boards orders in the public records and costs of satisfying and recording releases of the resulting lien upon payment

IT IS THEREFORE ORDERED AND ADJUDGED BY THE BOARD THAT

The violator is to have corrected the violation as of May 9 2019 The violator has not paid the initial civil penalty of $50000 There are continuing civil penalties that accrued from February 13 2017 through May 8 2019 for an amount due of $40750000 The violator is to pay to the City Clerks office within thirty (30) days of this Board order the continuing civil penalties of $40750000 the initial civil penalty of $50000 and the total costs of enforcement in the amount of

Page 1 of 2

Before me the undersigned authority personally appeared the Affiant Melody Sanderson who was duly sworn and who states that heshe has read the foregoing Affidavit of Costs and that the contents are true and correct

r Sworn to and subscribed before me this ~ayof ~ 20fl_ by Melody

Sanderson who is personally known to me OR __lL_ produced ____________ as identification

Jmf~~ NOTAAYPUBUC STATE OF FLORIDA Cfflri00022293 Expllfi 6182019

Page 2 of2

CUsersmsandersortVBPDDesktopletters and formsAffidavitsAffidavit Costs feb 08docx REVISED 2009docx

BEFORE THE CODE ENFORCEMENT BOARD OF THE CITY OF VERO BEACH FLORIDA

CITY OF VERO BEACH

vs

Abbassi Case Number 17-CE-7330 Violator

AFFIDAVIT OF COSTS STATE OF FLORIDA COUNTY OF INDIAN RIVER

I _Melody Sanderson being first duly sworn upon personal knowledge and information depose and state that I am a code enforcement or police officer for the City of Vero Beach Florida and I have personal knowledge of and certify that the City of Vero Beach has incurred the following administrative and prosecution costs in investigation enforcement testing or monitoring relating to the above-styled code enforcement case against the named violator and that the City ofVero Beach is entitled to recovery of said fees and costs from the violator pursuant to the code enforcement ordinance

Officer Activity Date Time Rate Amount $244285 MS Total hours 41317-61219 7378 $ 3311

MS Complaint Intake inc MS Initial Investigation inc MS Initial inspection inc MS Violator conference na MS Telephone conference na MS Hearing attendance inc MS Notice of violation preparation inc MS Notice ofhearing preparation inc MS Photoexhibit preparation inc MS Re-inspection inc

Additional Costs and Supplies na Postage na Notices (mailed and posted) inc T-ong nisfancP Telephone na Photographs inc Vehicle Mileage na

Total Costs $244285 1_~-~2-Vt

Melody Sanderson Affiant Officer

Before me the undersigned authority personally appeared the Affiant Melody Sanderson who was duly sworn and who states that heshe has read the foregoing Affidavit of Costs and that the contents are true and con-ect

Page 1 of2

CUsersmsancersonVBPDDesktopletters and fom1sAffidavisCosts 2018docx

l )Sworn to and subscribeg-bttlcrr~ me this

--7 day of JUtne 20_i_l by Melody

~ I -~--=~~----SanderSOfl who is personatfy knofff to me OR -- produced as identification I(__--

Page 2 of2

CUsersmsamlersonVBPDDesktopletters and formsAffidavitsCosts 2018docx

RECORDED IN THE PUBLIC RECORDS OF JEFFREY R SMITH CLERK OF COURT INDIAN RIVER COUNTY FL BK 3049 PG 2081 Page 1of28182017 121 PM

BEFORE THE CODE ENFORCEMENT BOARD OF THE CITY OF VERO BEACH FLORIDA

1053 20TH PLACE VERO BEACH FLORIDA 32960

CITY OF VERO BEACH CASE NO 17-CE-7330

VS CITATION NO 1034M

TONY AND LORANGEL ABBASSI 1643 Brickell Avenue Unit 2403 Miami Florida 33129

AMENDED ORDER FINDING VIOLATION DIRECTING CORRECTION AND PAYMENT OF CIVIL PENALTY AND COSTS AND IMPOSING CONTINUING

PENALTIES

VIOLATION City of Vero Beach Code sections 6011 6006 6102 6103 - operating a guest house and transient quarters in a residential zone LOCATION 3766 Ocean Drive Vero Beach Florida 32963

The above-styled case having come before the Code Enforcement Board of the City of Vero Beach (Board) on the 1ih day of April 2017 on request of the Code Officer for a Board Order Finding Violation and the Board having heard testimony of the Code Enforcement Officer and argument from the attorney for the City of Vero Beach and the violator regarding the violation and having reviewed the record in this action on motion made and approved found that

1 The citation and notice ofhearing in this case were served as provided by law

2 The violator did not appeal issuance of the citation in this case within the time allowed by law and thereby waived the right to a hearing before the Board to contest the issuance of the citation which waiver of hearing is deemed an admission of the violation specified in the citation The civil penalty in the amount of $50000 has not been paid

3 The City has requested enforcement costs in the amount of $44891 be assessed The City is entitled pursuant to law to recover all costs of recording the Boards orders in the public records and for satisfying and recording releases of the resulting liens upon payment

4 This Order replaces and supersedes the Order dated May 1 2017 recorded at Book 3029 Page 1596 in the Official Records of Indian River County due to a scriveners error in the recorded m~ - -

IT IS THEREFORE ORDERED AND ADJUDGED BY THE BOARD THAT

The violator is deemed to have committed the violation as specified above and on the citation There is hereby imposed the civil penalty of $50000 along with enforcement costs in the amount of $44391which shall be paid to the City Clerk within thirty (30) days from the date of this Order together with all costs incurred by the City for recording the Boards order in the public records and for

Page 1 of2

-iu~JHA5 uuu HAvrnmg nacase UI me resumng llens upon payment The violator shall correct the vi0lntio11 within 10 days from the Board order or a continuing civil penalty of $500 per day shall commence until the property is brought into compliance

DONE AND ORDERED at Vero Beach Indian River County Florida this 1~ day of ampvFt- 2011

ATTEST ctORCEME

Christophe

As Board Clerk Vice Chairman

[Seal]

Approved as to form and legal sufficiency

BY - ttCdeg DATE ftfrac12(ffrac12cf f ~1ampb~i

Kira C Honse --As Board Attorney

IMPORTANT INFORMATION

Payment of Civil Penalties and Costs You must contact the City Clerks office at 772-978-4700 for the total amount of civil penalties enforcement costs recording and other costs required to satisfy this order and lien Civil penalties and costs may be paid in person at the City Clerks office located in City Hall 1053 20th Place Vero Beach Florida 32960 Monday through Friday between 830 am and 500 pm or by mailing a check or money order to said address payable to City of Vero Beach Do not mail cash

Repeat Violation Repeat violation of the same Code provision by the violator even if committed at a different location can result in the issuance of a code enforcement citation and assessment of increased civil penalties for the repeat offense

Notice ofRight to Appeal Board Decision An aggrieved party may appeal the Boards order to the Circuit Court in Indian River County Florida A written notice of appeal together with a copy of the order appealed must be filed with the Clerk of the Code Enforcement Board and with the Clerk of the Circuit Court together with the applicable court filing fees within thirty (30) days after the date of this order or the right to appeal is waived An appeal is limited to appellate review of the record of the proceedings created before the Code Enforcement Board Ref FS 26012(1) Florida Rules of Appellate Procedure 9030(c)(l)(C) 91 I0(c)

Page 2 of2

JEFFREY R SMITH CLlKK Ur cuurlt I tNOIAN RIVER COUNTY FL BK 3228 PG 426 Page 1of2852019129 PM

BEFORETHECODEENFORCEMENTBOARD OF THE CITY OF VERO BEACH FLORIDA

I 053 20TH PLACE VERO BEACH FLORIDA 32960

CITY OF VERO BEACH CASE NO17-CE-7330

vs CITATION NO 1034M

TONY ABBASSI AND FLORANGEL ABBASSI 7171 Old Cutler Road Coral Gables Florida 33143

ORDER FINDING CORRECTION OF VIOLATION CEASING CONTINUING PENALTIES AND TO PAY PENALTIES AND COSTS

VIOLATION City of Vero Beach Code sections 6006 6011 6102 6103 - Operating a guest house and transient quarters in a residential zone LOCATION 3766 Ocean Drive Vero Beach Florida 32963

The above-styled case having come before the Code Enforcement Board of the City of Vero Beach (Board) on the 12th day of June 2019 on request of the Code Officer for a Board Order and the Board having heard testimony of the Code Officer and of the renting agent of the property and having reviewed the record in this action on motion made and approved found that

1 The notice ofhearing in this case was served as provided by law

2 The property was found to be in compliance on May 9 2019 by the Code Officer and continuing civil penalties accrued from February 13 2017 through May 08 2019 (day prior to finding properjy in compliance) a total of 815 days at $50000 per day for an amount due of $40750000

3 There is a cost of enforcement in the amount of $44891 as listed in the previous Board Order Finding Violation Directing Correction and Payment of Civil e_enalties and Costs and Imposing Continuing Penalties (21017 -41217)

4 There are additional costs of enforcement in the amount of $244285 ( 41317 - 61219) The initial civil penalty of $50000 remains unpaid

5 The City is entitled pursuant to law to recover all costs of recording the Boards orders in the public records and costs of satisfying and recording releases of the resulting lien upon payment

IT IS THEREFORE ORDERED AND ADJUDGED BY THE BOARD THAT

The violator is to have corrected the violation as of May 9 2019 The violator has not paid the initial civil penalty of $50000 There are continuing civil penalties that accrued from February 13 2017 through May 8 2019 for an amount due of $40750000 The violator is to pay to the City Clerks office within thirty (30) days of this Board order the continuing civil penalties of $40750000 the initial civil penalty of $50000 and the total costs of enforcement in the amount of

Page 1 of 2

BEFORE THE CODE ENFORCEMENT BOARD OF THE CITY OF VERO BEACH FLORIDA

CITY OF VERO BEACH

vs

Abbassi Case Number 17-CE-7330 Violator

AFFIDAVIT OF COSTS STATE OF FLORIDA COUNTY OF INDIAN RIVER

I _Melody Sanderson being first duly sworn upon personal knowledge and information depose and state that I am a code enforcement or police officer for the City of Vero Beach Florida and I have personal knowledge of and certify that the City of Vero Beach has incurred the following administrative and prosecution costs in investigation enforcement testing or monitoring relating to the above-styled code enforcement case against the named violator and that the City ofVero Beach is entitled to recovery of said fees and costs from the violator pursuant to the code enforcement ordinance

Officer Activity Date Time Rate Amount $244285 MS Total hours 41317-61219 7378 $ 3311

MS Complaint Intake inc MS Initial Investigation inc MS Initial inspection inc MS Violator conference na MS Telephone conference na MS Hearing attendance inc MS Notice of violation preparation inc MS Notice ofhearing preparation inc MS Photoexhibit preparation inc MS Re-inspection inc

Additional Costs and Supplies na Postage na Notices (mailed and posted) inc T-ong nisfancP Telephone na Photographs inc Vehicle Mileage na

Total Costs $244285 1_~-~2-Vt

Melody Sanderson Affiant Officer

Before me the undersigned authority personally appeared the Affiant Melody Sanderson who was duly sworn and who states that heshe has read the foregoing Affidavit of Costs and that the contents are true and con-ect

Page 1 of2

CUsersmsancersonVBPDDesktopletters and fom1sAffidavisCosts 2018docx

l )Sworn to and subscribeg-bttlcrr~ me this

--7 day of JUtne 20_i_l by Melody

~ I -~--=~~----SanderSOfl who is personatfy knofff to me OR -- produced as identification I(__--

Page 2 of2

CUsersmsamlersonVBPDDesktopletters and formsAffidavitsCosts 2018docx

RECORDED IN THE PUBLIC RECORDS OF JEFFREY R SMITH CLERK OF COURT INDIAN RIVER COUNTY FL BK 3049 PG 2081 Page 1of28182017 121 PM

BEFORE THE CODE ENFORCEMENT BOARD OF THE CITY OF VERO BEACH FLORIDA

1053 20TH PLACE VERO BEACH FLORIDA 32960

CITY OF VERO BEACH CASE NO 17-CE-7330

VS CITATION NO 1034M

TONY AND LORANGEL ABBASSI 1643 Brickell Avenue Unit 2403 Miami Florida 33129

AMENDED ORDER FINDING VIOLATION DIRECTING CORRECTION AND PAYMENT OF CIVIL PENALTY AND COSTS AND IMPOSING CONTINUING

PENALTIES

VIOLATION City of Vero Beach Code sections 6011 6006 6102 6103 - operating a guest house and transient quarters in a residential zone LOCATION 3766 Ocean Drive Vero Beach Florida 32963

The above-styled case having come before the Code Enforcement Board of the City of Vero Beach (Board) on the 1ih day of April 2017 on request of the Code Officer for a Board Order Finding Violation and the Board having heard testimony of the Code Enforcement Officer and argument from the attorney for the City of Vero Beach and the violator regarding the violation and having reviewed the record in this action on motion made and approved found that

1 The citation and notice ofhearing in this case were served as provided by law

2 The violator did not appeal issuance of the citation in this case within the time allowed by law and thereby waived the right to a hearing before the Board to contest the issuance of the citation which waiver of hearing is deemed an admission of the violation specified in the citation The civil penalty in the amount of $50000 has not been paid

3 The City has requested enforcement costs in the amount of $44891 be assessed The City is entitled pursuant to law to recover all costs of recording the Boards orders in the public records and for satisfying and recording releases of the resulting liens upon payment

4 This Order replaces and supersedes the Order dated May 1 2017 recorded at Book 3029 Page 1596 in the Official Records of Indian River County due to a scriveners error in the recorded m~ - -

IT IS THEREFORE ORDERED AND ADJUDGED BY THE BOARD THAT

The violator is deemed to have committed the violation as specified above and on the citation There is hereby imposed the civil penalty of $50000 along with enforcement costs in the amount of $44391which shall be paid to the City Clerk within thirty (30) days from the date of this Order together with all costs incurred by the City for recording the Boards order in the public records and for

Page 1 of2

-iu~JHA5 uuu HAvrnmg nacase UI me resumng llens upon payment The violator shall correct the vi0lntio11 within 10 days from the Board order or a continuing civil penalty of $500 per day shall commence until the property is brought into compliance

DONE AND ORDERED at Vero Beach Indian River County Florida this 1~ day of ampvFt- 2011

ATTEST ctORCEME

Christophe

As Board Clerk Vice Chairman

[Seal]

Approved as to form and legal sufficiency

BY - ttCdeg DATE ftfrac12(ffrac12cf f ~1ampb~i

Kira C Honse --As Board Attorney

IMPORTANT INFORMATION

Payment of Civil Penalties and Costs You must contact the City Clerks office at 772-978-4700 for the total amount of civil penalties enforcement costs recording and other costs required to satisfy this order and lien Civil penalties and costs may be paid in person at the City Clerks office located in City Hall 1053 20th Place Vero Beach Florida 32960 Monday through Friday between 830 am and 500 pm or by mailing a check or money order to said address payable to City of Vero Beach Do not mail cash

Repeat Violation Repeat violation of the same Code provision by the violator even if committed at a different location can result in the issuance of a code enforcement citation and assessment of increased civil penalties for the repeat offense

Notice ofRight to Appeal Board Decision An aggrieved party may appeal the Boards order to the Circuit Court in Indian River County Florida A written notice of appeal together with a copy of the order appealed must be filed with the Clerk of the Code Enforcement Board and with the Clerk of the Circuit Court together with the applicable court filing fees within thirty (30) days after the date of this order or the right to appeal is waived An appeal is limited to appellate review of the record of the proceedings created before the Code Enforcement Board Ref FS 26012(1) Florida Rules of Appellate Procedure 9030(c)(l)(C) 91 I0(c)

Page 2 of2

JEFFREY R SMITH CLlKK Ur cuurlt I tNOIAN RIVER COUNTY FL BK 3228 PG 426 Page 1of2852019129 PM

BEFORETHECODEENFORCEMENTBOARD OF THE CITY OF VERO BEACH FLORIDA

I 053 20TH PLACE VERO BEACH FLORIDA 32960

CITY OF VERO BEACH CASE NO17-CE-7330

vs CITATION NO 1034M

TONY ABBASSI AND FLORANGEL ABBASSI 7171 Old Cutler Road Coral Gables Florida 33143

ORDER FINDING CORRECTION OF VIOLATION CEASING CONTINUING PENALTIES AND TO PAY PENALTIES AND COSTS

VIOLATION City of Vero Beach Code sections 6006 6011 6102 6103 - Operating a guest house and transient quarters in a residential zone LOCATION 3766 Ocean Drive Vero Beach Florida 32963

The above-styled case having come before the Code Enforcement Board of the City of Vero Beach (Board) on the 12th day of June 2019 on request of the Code Officer for a Board Order and the Board having heard testimony of the Code Officer and of the renting agent of the property and having reviewed the record in this action on motion made and approved found that

1 The notice ofhearing in this case was served as provided by law

2 The property was found to be in compliance on May 9 2019 by the Code Officer and continuing civil penalties accrued from February 13 2017 through May 08 2019 (day prior to finding properjy in compliance) a total of 815 days at $50000 per day for an amount due of $40750000

3 There is a cost of enforcement in the amount of $44891 as listed in the previous Board Order Finding Violation Directing Correction and Payment of Civil e_enalties and Costs and Imposing Continuing Penalties (21017 -41217)

4 There are additional costs of enforcement in the amount of $244285 ( 41317 - 61219) The initial civil penalty of $50000 remains unpaid

5 The City is entitled pursuant to law to recover all costs of recording the Boards orders in the public records and costs of satisfying and recording releases of the resulting lien upon payment

IT IS THEREFORE ORDERED AND ADJUDGED BY THE BOARD THAT

The violator is to have corrected the violation as of May 9 2019 The violator has not paid the initial civil penalty of $50000 There are continuing civil penalties that accrued from February 13 2017 through May 8 2019 for an amount due of $40750000 The violator is to pay to the City Clerks office within thirty (30) days of this Board order the continuing civil penalties of $40750000 the initial civil penalty of $50000 and the total costs of enforcement in the amount of

Page 1 of 2

l )Sworn to and subscribeg-bttlcrr~ me this

--7 day of JUtne 20_i_l by Melody

~ I -~--=~~----SanderSOfl who is personatfy knofff to me OR -- produced as identification I(__--

Page 2 of2

CUsersmsamlersonVBPDDesktopletters and formsAffidavitsCosts 2018docx

RECORDED IN THE PUBLIC RECORDS OF JEFFREY R SMITH CLERK OF COURT INDIAN RIVER COUNTY FL BK 3049 PG 2081 Page 1of28182017 121 PM

BEFORE THE CODE ENFORCEMENT BOARD OF THE CITY OF VERO BEACH FLORIDA

1053 20TH PLACE VERO BEACH FLORIDA 32960

CITY OF VERO BEACH CASE NO 17-CE-7330

VS CITATION NO 1034M

TONY AND LORANGEL ABBASSI 1643 Brickell Avenue Unit 2403 Miami Florida 33129

AMENDED ORDER FINDING VIOLATION DIRECTING CORRECTION AND PAYMENT OF CIVIL PENALTY AND COSTS AND IMPOSING CONTINUING

PENALTIES

VIOLATION City of Vero Beach Code sections 6011 6006 6102 6103 - operating a guest house and transient quarters in a residential zone LOCATION 3766 Ocean Drive Vero Beach Florida 32963

The above-styled case having come before the Code Enforcement Board of the City of Vero Beach (Board) on the 1ih day of April 2017 on request of the Code Officer for a Board Order Finding Violation and the Board having heard testimony of the Code Enforcement Officer and argument from the attorney for the City of Vero Beach and the violator regarding the violation and having reviewed the record in this action on motion made and approved found that

1 The citation and notice ofhearing in this case were served as provided by law

2 The violator did not appeal issuance of the citation in this case within the time allowed by law and thereby waived the right to a hearing before the Board to contest the issuance of the citation which waiver of hearing is deemed an admission of the violation specified in the citation The civil penalty in the amount of $50000 has not been paid

3 The City has requested enforcement costs in the amount of $44891 be assessed The City is entitled pursuant to law to recover all costs of recording the Boards orders in the public records and for satisfying and recording releases of the resulting liens upon payment

4 This Order replaces and supersedes the Order dated May 1 2017 recorded at Book 3029 Page 1596 in the Official Records of Indian River County due to a scriveners error in the recorded m~ - -

IT IS THEREFORE ORDERED AND ADJUDGED BY THE BOARD THAT

The violator is deemed to have committed the violation as specified above and on the citation There is hereby imposed the civil penalty of $50000 along with enforcement costs in the amount of $44391which shall be paid to the City Clerk within thirty (30) days from the date of this Order together with all costs incurred by the City for recording the Boards order in the public records and for

Page 1 of2

-iu~JHA5 uuu HAvrnmg nacase UI me resumng llens upon payment The violator shall correct the vi0lntio11 within 10 days from the Board order or a continuing civil penalty of $500 per day shall commence until the property is brought into compliance

DONE AND ORDERED at Vero Beach Indian River County Florida this 1~ day of ampvFt- 2011

ATTEST ctORCEME

Christophe

As Board Clerk Vice Chairman

[Seal]

Approved as to form and legal sufficiency

BY - ttCdeg DATE ftfrac12(ffrac12cf f ~1ampb~i

Kira C Honse --As Board Attorney

IMPORTANT INFORMATION

Payment of Civil Penalties and Costs You must contact the City Clerks office at 772-978-4700 for the total amount of civil penalties enforcement costs recording and other costs required to satisfy this order and lien Civil penalties and costs may be paid in person at the City Clerks office located in City Hall 1053 20th Place Vero Beach Florida 32960 Monday through Friday between 830 am and 500 pm or by mailing a check or money order to said address payable to City of Vero Beach Do not mail cash

Repeat Violation Repeat violation of the same Code provision by the violator even if committed at a different location can result in the issuance of a code enforcement citation and assessment of increased civil penalties for the repeat offense

Notice ofRight to Appeal Board Decision An aggrieved party may appeal the Boards order to the Circuit Court in Indian River County Florida A written notice of appeal together with a copy of the order appealed must be filed with the Clerk of the Code Enforcement Board and with the Clerk of the Circuit Court together with the applicable court filing fees within thirty (30) days after the date of this order or the right to appeal is waived An appeal is limited to appellate review of the record of the proceedings created before the Code Enforcement Board Ref FS 26012(1) Florida Rules of Appellate Procedure 9030(c)(l)(C) 91 I0(c)

Page 2 of2

JEFFREY R SMITH CLlKK Ur cuurlt I tNOIAN RIVER COUNTY FL BK 3228 PG 426 Page 1of2852019129 PM

BEFORETHECODEENFORCEMENTBOARD OF THE CITY OF VERO BEACH FLORIDA

I 053 20TH PLACE VERO BEACH FLORIDA 32960

CITY OF VERO BEACH CASE NO17-CE-7330

vs CITATION NO 1034M

TONY ABBASSI AND FLORANGEL ABBASSI 7171 Old Cutler Road Coral Gables Florida 33143

ORDER FINDING CORRECTION OF VIOLATION CEASING CONTINUING PENALTIES AND TO PAY PENALTIES AND COSTS

VIOLATION City of Vero Beach Code sections 6006 6011 6102 6103 - Operating a guest house and transient quarters in a residential zone LOCATION 3766 Ocean Drive Vero Beach Florida 32963

The above-styled case having come before the Code Enforcement Board of the City of Vero Beach (Board) on the 12th day of June 2019 on request of the Code Officer for a Board Order and the Board having heard testimony of the Code Officer and of the renting agent of the property and having reviewed the record in this action on motion made and approved found that

1 The notice ofhearing in this case was served as provided by law

2 The property was found to be in compliance on May 9 2019 by the Code Officer and continuing civil penalties accrued from February 13 2017 through May 08 2019 (day prior to finding properjy in compliance) a total of 815 days at $50000 per day for an amount due of $40750000

3 There is a cost of enforcement in the amount of $44891 as listed in the previous Board Order Finding Violation Directing Correction and Payment of Civil e_enalties and Costs and Imposing Continuing Penalties (21017 -41217)

4 There are additional costs of enforcement in the amount of $244285 ( 41317 - 61219) The initial civil penalty of $50000 remains unpaid

5 The City is entitled pursuant to law to recover all costs of recording the Boards orders in the public records and costs of satisfying and recording releases of the resulting lien upon payment

IT IS THEREFORE ORDERED AND ADJUDGED BY THE BOARD THAT

The violator is to have corrected the violation as of May 9 2019 The violator has not paid the initial civil penalty of $50000 There are continuing civil penalties that accrued from February 13 2017 through May 8 2019 for an amount due of $40750000 The violator is to pay to the City Clerks office within thirty (30) days of this Board order the continuing civil penalties of $40750000 the initial civil penalty of $50000 and the total costs of enforcement in the amount of

Page 1 of 2

RECORDED IN THE PUBLIC RECORDS OF JEFFREY R SMITH CLERK OF COURT INDIAN RIVER COUNTY FL BK 3049 PG 2081 Page 1of28182017 121 PM

BEFORE THE CODE ENFORCEMENT BOARD OF THE CITY OF VERO BEACH FLORIDA

1053 20TH PLACE VERO BEACH FLORIDA 32960

CITY OF VERO BEACH CASE NO 17-CE-7330

VS CITATION NO 1034M

TONY AND LORANGEL ABBASSI 1643 Brickell Avenue Unit 2403 Miami Florida 33129

AMENDED ORDER FINDING VIOLATION DIRECTING CORRECTION AND PAYMENT OF CIVIL PENALTY AND COSTS AND IMPOSING CONTINUING

PENALTIES

VIOLATION City of Vero Beach Code sections 6011 6006 6102 6103 - operating a guest house and transient quarters in a residential zone LOCATION 3766 Ocean Drive Vero Beach Florida 32963

The above-styled case having come before the Code Enforcement Board of the City of Vero Beach (Board) on the 1ih day of April 2017 on request of the Code Officer for a Board Order Finding Violation and the Board having heard testimony of the Code Enforcement Officer and argument from the attorney for the City of Vero Beach and the violator regarding the violation and having reviewed the record in this action on motion made and approved found that

1 The citation and notice ofhearing in this case were served as provided by law

2 The violator did not appeal issuance of the citation in this case within the time allowed by law and thereby waived the right to a hearing before the Board to contest the issuance of the citation which waiver of hearing is deemed an admission of the violation specified in the citation The civil penalty in the amount of $50000 has not been paid

3 The City has requested enforcement costs in the amount of $44891 be assessed The City is entitled pursuant to law to recover all costs of recording the Boards orders in the public records and for satisfying and recording releases of the resulting liens upon payment

4 This Order replaces and supersedes the Order dated May 1 2017 recorded at Book 3029 Page 1596 in the Official Records of Indian River County due to a scriveners error in the recorded m~ - -

IT IS THEREFORE ORDERED AND ADJUDGED BY THE BOARD THAT

The violator is deemed to have committed the violation as specified above and on the citation There is hereby imposed the civil penalty of $50000 along with enforcement costs in the amount of $44391which shall be paid to the City Clerk within thirty (30) days from the date of this Order together with all costs incurred by the City for recording the Boards order in the public records and for

Page 1 of2

-iu~JHA5 uuu HAvrnmg nacase UI me resumng llens upon payment The violator shall correct the vi0lntio11 within 10 days from the Board order or a continuing civil penalty of $500 per day shall commence until the property is brought into compliance

DONE AND ORDERED at Vero Beach Indian River County Florida this 1~ day of ampvFt- 2011

ATTEST ctORCEME

Christophe

As Board Clerk Vice Chairman

[Seal]

Approved as to form and legal sufficiency

BY - ttCdeg DATE ftfrac12(ffrac12cf f ~1ampb~i

Kira C Honse --As Board Attorney

IMPORTANT INFORMATION

Payment of Civil Penalties and Costs You must contact the City Clerks office at 772-978-4700 for the total amount of civil penalties enforcement costs recording and other costs required to satisfy this order and lien Civil penalties and costs may be paid in person at the City Clerks office located in City Hall 1053 20th Place Vero Beach Florida 32960 Monday through Friday between 830 am and 500 pm or by mailing a check or money order to said address payable to City of Vero Beach Do not mail cash

Repeat Violation Repeat violation of the same Code provision by the violator even if committed at a different location can result in the issuance of a code enforcement citation and assessment of increased civil penalties for the repeat offense

Notice ofRight to Appeal Board Decision An aggrieved party may appeal the Boards order to the Circuit Court in Indian River County Florida A written notice of appeal together with a copy of the order appealed must be filed with the Clerk of the Code Enforcement Board and with the Clerk of the Circuit Court together with the applicable court filing fees within thirty (30) days after the date of this order or the right to appeal is waived An appeal is limited to appellate review of the record of the proceedings created before the Code Enforcement Board Ref FS 26012(1) Florida Rules of Appellate Procedure 9030(c)(l)(C) 91 I0(c)

Page 2 of2

JEFFREY R SMITH CLlKK Ur cuurlt I tNOIAN RIVER COUNTY FL BK 3228 PG 426 Page 1of2852019129 PM

BEFORETHECODEENFORCEMENTBOARD OF THE CITY OF VERO BEACH FLORIDA

I 053 20TH PLACE VERO BEACH FLORIDA 32960

CITY OF VERO BEACH CASE NO17-CE-7330

vs CITATION NO 1034M

TONY ABBASSI AND FLORANGEL ABBASSI 7171 Old Cutler Road Coral Gables Florida 33143

ORDER FINDING CORRECTION OF VIOLATION CEASING CONTINUING PENALTIES AND TO PAY PENALTIES AND COSTS

VIOLATION City of Vero Beach Code sections 6006 6011 6102 6103 - Operating a guest house and transient quarters in a residential zone LOCATION 3766 Ocean Drive Vero Beach Florida 32963

The above-styled case having come before the Code Enforcement Board of the City of Vero Beach (Board) on the 12th day of June 2019 on request of the Code Officer for a Board Order and the Board having heard testimony of the Code Officer and of the renting agent of the property and having reviewed the record in this action on motion made and approved found that

1 The notice ofhearing in this case was served as provided by law

2 The property was found to be in compliance on May 9 2019 by the Code Officer and continuing civil penalties accrued from February 13 2017 through May 08 2019 (day prior to finding properjy in compliance) a total of 815 days at $50000 per day for an amount due of $40750000

3 There is a cost of enforcement in the amount of $44891 as listed in the previous Board Order Finding Violation Directing Correction and Payment of Civil e_enalties and Costs and Imposing Continuing Penalties (21017 -41217)

4 There are additional costs of enforcement in the amount of $244285 ( 41317 - 61219) The initial civil penalty of $50000 remains unpaid

5 The City is entitled pursuant to law to recover all costs of recording the Boards orders in the public records and costs of satisfying and recording releases of the resulting lien upon payment

IT IS THEREFORE ORDERED AND ADJUDGED BY THE BOARD THAT

The violator is to have corrected the violation as of May 9 2019 The violator has not paid the initial civil penalty of $50000 There are continuing civil penalties that accrued from February 13 2017 through May 8 2019 for an amount due of $40750000 The violator is to pay to the City Clerks office within thirty (30) days of this Board order the continuing civil penalties of $40750000 the initial civil penalty of $50000 and the total costs of enforcement in the amount of

Page 1 of 2

-iu~JHA5 uuu HAvrnmg nacase UI me resumng llens upon payment The violator shall correct the vi0lntio11 within 10 days from the Board order or a continuing civil penalty of $500 per day shall commence until the property is brought into compliance

DONE AND ORDERED at Vero Beach Indian River County Florida this 1~ day of ampvFt- 2011

ATTEST ctORCEME

Christophe

As Board Clerk Vice Chairman

[Seal]

Approved as to form and legal sufficiency

BY - ttCdeg DATE ftfrac12(ffrac12cf f ~1ampb~i

Kira C Honse --As Board Attorney

IMPORTANT INFORMATION

Payment of Civil Penalties and Costs You must contact the City Clerks office at 772-978-4700 for the total amount of civil penalties enforcement costs recording and other costs required to satisfy this order and lien Civil penalties and costs may be paid in person at the City Clerks office located in City Hall 1053 20th Place Vero Beach Florida 32960 Monday through Friday between 830 am and 500 pm or by mailing a check or money order to said address payable to City of Vero Beach Do not mail cash

Repeat Violation Repeat violation of the same Code provision by the violator even if committed at a different location can result in the issuance of a code enforcement citation and assessment of increased civil penalties for the repeat offense

Notice ofRight to Appeal Board Decision An aggrieved party may appeal the Boards order to the Circuit Court in Indian River County Florida A written notice of appeal together with a copy of the order appealed must be filed with the Clerk of the Code Enforcement Board and with the Clerk of the Circuit Court together with the applicable court filing fees within thirty (30) days after the date of this order or the right to appeal is waived An appeal is limited to appellate review of the record of the proceedings created before the Code Enforcement Board Ref FS 26012(1) Florida Rules of Appellate Procedure 9030(c)(l)(C) 91 I0(c)

Page 2 of2

JEFFREY R SMITH CLlKK Ur cuurlt I tNOIAN RIVER COUNTY FL BK 3228 PG 426 Page 1of2852019129 PM

BEFORETHECODEENFORCEMENTBOARD OF THE CITY OF VERO BEACH FLORIDA

I 053 20TH PLACE VERO BEACH FLORIDA 32960

CITY OF VERO BEACH CASE NO17-CE-7330

vs CITATION NO 1034M

TONY ABBASSI AND FLORANGEL ABBASSI 7171 Old Cutler Road Coral Gables Florida 33143

ORDER FINDING CORRECTION OF VIOLATION CEASING CONTINUING PENALTIES AND TO PAY PENALTIES AND COSTS

VIOLATION City of Vero Beach Code sections 6006 6011 6102 6103 - Operating a guest house and transient quarters in a residential zone LOCATION 3766 Ocean Drive Vero Beach Florida 32963

The above-styled case having come before the Code Enforcement Board of the City of Vero Beach (Board) on the 12th day of June 2019 on request of the Code Officer for a Board Order and the Board having heard testimony of the Code Officer and of the renting agent of the property and having reviewed the record in this action on motion made and approved found that

1 The notice ofhearing in this case was served as provided by law

2 The property was found to be in compliance on May 9 2019 by the Code Officer and continuing civil penalties accrued from February 13 2017 through May 08 2019 (day prior to finding properjy in compliance) a total of 815 days at $50000 per day for an amount due of $40750000

3 There is a cost of enforcement in the amount of $44891 as listed in the previous Board Order Finding Violation Directing Correction and Payment of Civil e_enalties and Costs and Imposing Continuing Penalties (21017 -41217)

4 There are additional costs of enforcement in the amount of $244285 ( 41317 - 61219) The initial civil penalty of $50000 remains unpaid

5 The City is entitled pursuant to law to recover all costs of recording the Boards orders in the public records and costs of satisfying and recording releases of the resulting lien upon payment

IT IS THEREFORE ORDERED AND ADJUDGED BY THE BOARD THAT

The violator is to have corrected the violation as of May 9 2019 The violator has not paid the initial civil penalty of $50000 There are continuing civil penalties that accrued from February 13 2017 through May 8 2019 for an amount due of $40750000 The violator is to pay to the City Clerks office within thirty (30) days of this Board order the continuing civil penalties of $40750000 the initial civil penalty of $50000 and the total costs of enforcement in the amount of

Page 1 of 2

JEFFREY R SMITH CLlKK Ur cuurlt I tNOIAN RIVER COUNTY FL BK 3228 PG 426 Page 1of2852019129 PM

BEFORETHECODEENFORCEMENTBOARD OF THE CITY OF VERO BEACH FLORIDA

I 053 20TH PLACE VERO BEACH FLORIDA 32960

CITY OF VERO BEACH CASE NO17-CE-7330

vs CITATION NO 1034M

TONY ABBASSI AND FLORANGEL ABBASSI 7171 Old Cutler Road Coral Gables Florida 33143

ORDER FINDING CORRECTION OF VIOLATION CEASING CONTINUING PENALTIES AND TO PAY PENALTIES AND COSTS

VIOLATION City of Vero Beach Code sections 6006 6011 6102 6103 - Operating a guest house and transient quarters in a residential zone LOCATION 3766 Ocean Drive Vero Beach Florida 32963

The above-styled case having come before the Code Enforcement Board of the City of Vero Beach (Board) on the 12th day of June 2019 on request of the Code Officer for a Board Order and the Board having heard testimony of the Code Officer and of the renting agent of the property and having reviewed the record in this action on motion made and approved found that

1 The notice ofhearing in this case was served as provided by law

2 The property was found to be in compliance on May 9 2019 by the Code Officer and continuing civil penalties accrued from February 13 2017 through May 08 2019 (day prior to finding properjy in compliance) a total of 815 days at $50000 per day for an amount due of $40750000

3 There is a cost of enforcement in the amount of $44891 as listed in the previous Board Order Finding Violation Directing Correction and Payment of Civil e_enalties and Costs and Imposing Continuing Penalties (21017 -41217)

4 There are additional costs of enforcement in the amount of $244285 ( 41317 - 61219) The initial civil penalty of $50000 remains unpaid

5 The City is entitled pursuant to law to recover all costs of recording the Boards orders in the public records and costs of satisfying and recording releases of the resulting lien upon payment

IT IS THEREFORE ORDERED AND ADJUDGED BY THE BOARD THAT

The violator is to have corrected the violation as of May 9 2019 The violator has not paid the initial civil penalty of $50000 There are continuing civil penalties that accrued from February 13 2017 through May 8 2019 for an amount due of $40750000 The violator is to pay to the City Clerks office within thirty (30) days of this Board order the continuing civil penalties of $40750000 the initial civil penalty of $50000 and the total costs of enforcement in the amount of

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$289176 for a total amount due of $41089176 together with all costs of recording the Boards orders in the public records and costs of satisfying and recording releases of the resulting lien upon payment

DONE AND ORDERED at Vero Beach Indian River County Florida this 3 rrl day of ~u J _1 2019

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Sherri Philo Eric Price as Board Clerk as Board Vice-Chairman

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IMPORTANT INFORMATION Correction of Violations AFTER CORRECTING THE VIOLATIONS YOU MUST NOTIFY THE CODE ENFORCEMENT OFFICER by Telephone 772-978-4551 or 772-978-4561 or in person at the Code Enforcement Office Vero Beach Police Department 1055 20th Street Vero Beach FL 32960 in order to request re-inspection to avoid imposition of additional civil penalties against you

Payment of Civil Penalties and Costs You must contact the City Clerks office at 772-978-4700 for the total amount of civil penalties enforcement costs recording and other costs required to satisfy this order and lien Civil penalties and costs may be paid in person at the City Clerks office located in City Hall 1053 20th Place Vero Beach Florida 32960 Monday through Friday between 830 am and 500 pm or by mailing a check or money order to said address payable to City of Vero Beach Do not mail cash

Repeat Violation Repeat violation of the same Code provision by the violator even if committed at a different location can result in the issuance of a code enforcement citation and assessment of increased civil penalties for the repeat offense

Notice ofRight to Appeal Board Decision An aggrieved party may appeal the Boards order to the Circuit Court in Indian River County Florida A written notice of appeal together with a copy of the order appealed must be filed with the Clerk of the Code Enforcement Board and with the Clerk of the Circuit Court together with the applicable court filing fees within thirty (30) days after the date of this order or the right to appeal is waived An appeal is limited to appellate review of the record of the proceedings created before the Code Enforcement Board Ref FS 26012(1) Florida Rules of Appellate Procedure 9030(c)(l)(C) 91 l0(c)

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CIT OF VERO Bamp1-CH fLORIDA CODE ENFORCEJvIENT BOtJ-ii-ru

CITY OF VERO BEACH CASENO 17-CE-7330 Citation No 1034tvI

TONt ABBASSI ancl FLORANGEL ]3BASSI

NOTICE (F APPEAL

N(YI1CE IS GPEN that lf)N ABBASSI and FLORtlfGEL ABBASSI~

Ordi11ru1ces tu11dy apreals to the Chmiddotcttlt Court of the Nh1eteen-th J1t1dicfal Chmiddotc1tlt

hereto TI1c naturc of the July 3 2019 Orckr Fmding Correction ofViolation

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the City ofVero Beach Code Enforcemcnt Board

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