Loading...
2025-06RESOLUTION NO. 2025-06 A RESOLUTION OF THE VILLAGE COUNCIL OF MIAMI SHORES VILLAGE, FLORIDA, APPROVING THE STATEMENT OF ALLOWABLE USES, RESPONSE, AND SETTLEMENT OFFER IN RESPONSE TO THE CLAIM FILED BY BLUENEST HOMES, INC. UNDER THE BERT J. HARRIS, JR., PRIVATE PROPERTY RIGHTS PROTECTION ACT; AND PROVIDING FOR FINDINGS, APPROVAL, AUTHORIZATION, AND AN EFFECTIVE DATE. WHEREAS, Miami Shores Village (the "Village") Council acknowledges the receipt of a notice of claim filed under the Bert J. Harris, Jr., Private Property Rights Protection Act, Section 70.001, Florida Statutes (the "Act); and WHEREAS, the claim was submitted by Bluenest Homes, Inc. on November 27, 2024 concerning properties located at 9305 NE 91' Avenue (RSP-24-37) and 78 NE 981h Street (RSP-24-48) (collectively referred to as "the Subject Properties"); and WHEREAS, the claim alleges that governmental action has inordinately burdened the Subject Properties, and the claimant seeks relief pursuant to the Act; and WHEREAS, the Village has reviewed and evaluated the claim, and obtained legal and professional analyses regarding the claim; and WHEREAS, pursuant to Section 70.001(4)-(5), Florida Statutes, within ninety (90) days of receipt of a notice of claim under the Act, the Village must make a written settlement offer and issue a written statement of allowable uses to the property owner that submitted the claim; and WHEREAS, after due consideration, the Village finds it appropriate to respond to the claim submitted by Bluenest Homes, Inc., as provided in the response attached as EExhibit A;❑and WHEREAS, the Village Council finds that this Resolution is in the best interest and welfare of the residents of the Village. NOW, THEREFORE, BE IT RESOLVED BY THE VILLAGE COUNCIL OF MIAMI SHORES VILLAGE, FLORIDA, AS FOLLOWS: Section 1. Recitals Adopted., The foregoing recitals are true and correct. Section 2. Approval. The Village Council approves the response to the Bert J. Harris Act claim, as outlined in the attached document (Exhibit A), including the Settlement Offer contained therein. Section 3. Authorization and Implementation. The Village Attorney Office is authorized to execute and deliver the approved response on behalf of the Village and take all necessary actions to implement the intent of this Resolution. Section 4. Effective Date. This Resolution shall take effect immediately upon the adoption hereof. PASSED AND ADOPTED this 18 day of February, 2025. Mayor George Burch, APPROVED AS TO FORM AND LEGAL SUFFICIENCY: A/ illage Attor Weiss Serota Helfman Cole & Bierman P.L. EXHIBIT A yz _ SEROTA HELFMAN COLE + BIERMAN ALICIA GONZALEZ, PARTNER agonzalez@wish-Law.com 1954-763-4242 February 10, 2025 Via FedEx-Next Day Delivery: US Airbill: 772177695925 & Email: martin.alexandernhklaw.com Bluenest Homes, Inc. c/o Martin J. Alexander, Esq. Holland & Knight, LLP 515 E. Las Olas Blvd. Suite 1200 Fort Lauderdale, FL 33301 Email: martin.alexander@hklaw.com RE: Section 70.001, Florida Statutes ("Bert Harris Act" or "Act") Claim by Bluenest Homes, Inc. ("Bluenest") related to the real property located at 9305 NE 911 Avenue, Miami Shores Village ("9305 Property") and 78 NE 9811 Street, Miami Shores Village ("78 Property"), collectively "Subject Properties" Dear Mr. Alexander: This letter is in response to the Bluenest's November 27, 2024, Bert Harris Act Claim, which is premised on Miami Shores Village's ("Village") change of the land development regulations applicable to the Subject Properties (referred to in the claim letter as the "New Zoning Ordinance"). As provided in section 70.001(5)(a), Florida Statutes, the Village hereby identifies the "allowable uses to which the [Subject Properties] may be put." This letter is also intended to act as the Village's settlement offer to the Bluenest pursuant to section 70.001(4)(c), Florida Statutes. The uses set forth in this letter are subject to all applicable development regulations, development approvals, and all related procedures. The uses stated in the letter are the "by right" uses permissible on the Subject Properties, and this letter does not in any way limit Bluenest's ability or right to pursue variances, waivers, and or land use and zoning changes as permitted under the code by proper application. This letter does not operate to, and is not intended to, vest any rights to develop the Subject Properties or to put the Subject Properties to a particular use. Further, by issuing this letter, the Village does not acknowledge or concede that Bluenest's claim is valid or gives rise to a cause of action which would entitle Bluenest to relief under the Bert Harris Act or any other applicable law. This letter is based on the Village's good faith review and consideration of Bluenest's claim. The Village expressly reserves the right to raise or elaborate on any further arguments or grounds in favor of its, position in the future. Statement of Allowable Uses The 9305 Property is legally described as follows: LOT 8, MARILYN HEIGHTS A SUBDIVISION, ACCORDING TO THE MAP OR PLAT THEREOF, IN PLAT BOOK 41, AT PAGE 8, OF THE PUBLIC RECORDS OF MIAMI-DADE COUNTY, FLORIDA. PARCEL IDENTIFICATION NUMBER: 11-3206-001-0080 The 78 Property is legally described as follows: LOTS 3, 4 AND THE EAST HALF OF LOT 5, SHORES SECTION NO. 1, ACCORDING T RECORDED IN PLAT BOOK 10, PAGE 70, COUNTY, FLORIDA O BLOCK 7, AMENDED PLAT OF MAIMI THE MAP OR PLAT THEREOF AS PUBLIC RECORDS OF MIAMI-DADE PARCEL IDENTIFICATION NUMBER: 11-3206-013-0900 The 9305 Property consists of approximately 9,600 square feet of land that is currently improved with a single-family home. The 78 Property consists of approximately 14,375 square feet of land that is currently improved with a single-family home. The Subject Properties have the same future land use designation, which is Single Family Residential. The Single -Family Residential FLU designation permits the following uses: The residential densities allowed in this category shall not exceed 2.5 dwelling units per gross acre. This density category is characterized solely by detached single family homes on relatively large lots. The 9305 Property has a zoning designation of One -family residential district (R16.5), and the 78 Property has a zoning designation of One -family residential districts (RI 8.5). The permitted uses are listed in the attached Exhibit "A." Permitted uses are limited by the requirements in Art. V, Div. 7 §523 and Art. VI §604, of the Village Code of Ordinances ("Village Code"), which gives the Village discretion to require that any new development be harmonious with existing development in the neighborhood. Specifically, Section 523 requires "[a]ll buildings ... be generally harmonious in character and appearance ... with existing buildings in the neighborhood and ... be appropriate to their surroundings." Section 604 similarly provides that "[i]n acting on a site plan, the planning and zoning board shall ... [m]ake such requirements with respect to the following matters: (a) Building design and location, including setbacks if deemed advisable... as will assure harmonious relation between the uses to which the site plan applies and existing and prospective residential and other development in the vicinity." 2 Development on the Subject Properties is also required to be consistent with the Village Comprehensive Plan and the Village's Land Development Regulations for particular developments (including setbacks, parking, landscaping, etc.). The development must also comply with any restrictions of other government entities having jurisdiction over the Subject Properties. Response to the Bert Harris Act Claim Bluenest alleges that the Village's enactment of the New Zoning Ordinance has reduced the fair market value of the 9305 Property by $2,050,000 and has reduced the fair market value of the 78 Property by $600,000. Bluenest contends that prior to the enactment of the New Zoning Ordinance, the 9305 Property could be developed with the 5,045 square foot residence proposed in its May 10, 2024 Application ("9305 Property Application"), and after the enactment of the New Zoning Ordinance, the 9305 Property could be developed only with a 4,036 square foot residence. Bluenest contends that the alleged 739 SF reduction results in a $2,050,000 reduction in the value of the 9305 Property. Bluenest further contends that, prior to enactment of the New Zoning Ordinance, the 78 Property could be developed with a 6,404 square foot residence proposed in its June 3, 2024 application ("78 Property Application"), and after the enactment of the New Zoning Ordinance the 78 Property could be developed only with a 5,688 square foot residence. Bluenest contends that the alleged 716 SF reduction results in a $600,000 reduction in property value. The Village's Position Regarding Bluenest's Bert Harris Act Claim The following is offered without limitation in response to Bluenest's Bert Harris Act Claim, and the Village expressly reserves the right to raise additional arguments and defenses related to the Bluenest's claim: 1. BLUENEST HAS MISREPRESENTED FACTS IN ITS CLAIM LETTER. Clarification is warranted on Bluenest's misrepresentations of facts in its claim letter. The claim letter contends that the Village Planning & Zoning Board ("Board") did not apply the Previous Code to the 9305 Property Application when it decided to table the application but rather applied the New Zoning Ordinance, which had not yet been enacted. Claim Ltr. P. 5. This is incorrect. The 9305 Property Application was evaluated under the Previous Code as it stood at the time that the application was considered - not the New Zoning Code. However, the Board found that the proposed development in the 9305 Property Application was inharmonious with the existing neighborhood for several reasons and decided to table the application. Tabling would permit Bluenest to modify the application to make it harmonious before resubmitting the application for reconsideration. Bluenest agreed to have the application tabled to make the suggested adjustments, rather than requesting denial to immediately trigger its right to appeal the "Previous Code" refers to the Village Code, including its zoning code and land development regulations, as it existed before the New Zoning Ordinance that is the subject of Bluenest's claim was enacted. Board's decision.2 A denial would have permitted immediate appeal to the Village Council. If Bluenest truly believed that its application should have been approved, it would have pursued this avenue, but it did not. Had it chosen to appeal the denial, the review would have been under the Previous Code; not the New Zoning Ordinance. Because it instead elected to table the item, consideration was postponed such that the New Zoning Ordinance came into effect and was then applicable to the revised 9305 Property Application. As such, Bluenest chose this avenue. The claim letter implies that the 78 Property Application was tabled at the July 25, 2024 meeting because the New Zoning Ordinance was being applied to restrict the size of the development and/or so that the New Zoning Ordinance would apply upon the required resubmission of the 78 Property Application. This, again, is inaccurate. The Board asked Bluenest whether it would like the application to tabled or denied because the application, as submitted, was deemed inharmonious with the neighborhood under the Previous Code. Bluenest requested and was granted five minutes to confer and decide what it wanted to do. Bluenest requested that the application be tabled rather than denied. A denial would have given Bluenest immediate appeal rights under the provisions of the Previous Code. If Bluenest truly believed that it was entitled to approval by right under the Previous Code and that the Board was acting illegally, then it should have taken the denial and appealed. In fact, Bluenest knew that the Board had the authority under the Previous Code to deny the application as inharmonious, thus it elected to have the application tabled. Finally, Bluenest claims that at the September 19, 2024 meeting, it requested for a "third time" that both site plan applications be untabled. This, again, is inaccurate. Bluenest's representative appeared to request for the second time that the 9305 Property Application be untabled, and for the first time that the 78 Property Application be untabled. At that meeting, the Board explained that applications are tabled to allow the applicant to address Board comments and avoid denial of the application. Upon tabling, applicants generally address the Board's comments by revising their plans and proceed to resubmit a revised application with the revisions for consideration by the Board. Thus, the item is untabled upon resubmission of a revised application. However, because of the timing on Bluenest's resubmission, the New Zoning Ordinance had taken effect, and Bluenest would be subject to the New Zoning Ordinance upon resubmission. Bluenest could have avoided this result had it requested a denial of its application. Instead, while represented by attorneys, Bluenest chose to have its application tabled. When the Board denies a site plan application, an applicant can appeal the decision to the Village Council within thirty days of the denial. Village Code, Art. VIII §800. If the Village Council agrees with the appealing party, it can overturn the Board's decision. Id. If the Village Council were to affirm the Board's decision, Bluenest could file a Petition for Writ of Certiorari, in which a circuit court would review the Village Council's decision to determine whether procedural due process was accorded, whether the essential requirements of the law were observed, and whether the Council's findings were supported by substantial and competent evidence. Parker Family Tr. I v. City ofdacksonville, 804 So. 2d 493, 497 (Fla. 1st DCA 2001). If, in fact, Bluenest believed that its application should have been approved under the Existing Code, it should have elected this option as it would have been guaranteed success (assuming it was correct in its assumption that it was guaranteed approval under the Existing Code, which it is not). Instead, it delayed its application such that, ultimately, the Village had no choice but to apply the New Zoning Ordinance to its applications. 4 2. BLUENEST DID NOT HAVE AN EXISTING USE TO DEVELOP THE 9305 PROPERTY WITH A 5,045 SQUARE FOOT RESIDENCE AND TO DEVELOP 78 PROPERTY WITH A 6,404 SQUARE FOOT RESIDENCE. Bluenest did not have an "existing use" to develop the 9305 Property with a 6,404 square foot residence and to develop the 78 Property with a 5,054 square foot residence ("Proposed Development") because the permissible uses in the zoning code are all subject to the requirement that development be harmonious with the neighborhood. The Proposed Development is not harmonious with the Subject Properties' respective neighborhoods. An "existing use" can be an "[a]ctivity or such reasonably foreseeable, nonspeculative land uses which are suitable for the subject real property and compatible with adjacent land uses and which have created an existing fair market value in the property greater than the fair market value of the actual, present use or activity on the real property." Although prior to enactment of the New Zoning Ordinance, the Subject Properties were not subject to any specific floor area ratio or lot coverage restrictions in the zoning code, the requirement that any development be harmonious with the neighborhood still existed and was consistently applied to restrict floor area ration ("FAR") and lot coverage for residential development.3 The proposed designs for the Subject Properties were inconsistent and inharmonious with the houses in the Subject Properties' respective neighborhoods. As such, Bluenest did not have an existing use in the proposed developments because the larger residences that Bluenest proposed to construct on the Subject Properties were not harmonious with existing development in their respective neighborhoods. The Code, as it existed before the New Zoning Ordinance was enacted, restricted such development, but also, the Harris Act does not recognize such development as an "existing use" because, to constitute an existing use, the development must be "reasonably foreseeable," nonspeculative, and compatible with adjacent land uses. The proposed residences on the Subject Properties are much more expansive than any existing development in the neighborhoods, and therefore were not reasonably foreseeable or nonspeculative as they cannot be considered harmonious with their respective neighborhoods. For the same reasons, the Proposed Development cannot be considered compatible with adjacent land uses, and as a result, cannot be considered an "existing use" under the Act. As such, Bluenest's Bert Harris Act claim must fail. 3. THE NEW ZONING ORDINANCE DID NOT INORDINATELY BURDEN THE SUBJECT PROPERTIES. 3 Specifically, Art. VI §604 of the Village Code, requires the Board, when acting on a site plan, to, among other things, make requirements with respect to building design "including setbacks ... as will assure a harmonious relation between the uses to which the site plan applies and the existing and prospective residential and other developments in the vicinity." The requirement that development be harmonious is also contained in Div. 7, § 523, of the Village Code, which provides that "buildings shall generally be harmonious in character and appearance ... with existing buildings in the neighborhood and shall be appropriate to their surroundings." Proposed buildings that are "inharmonious or inappropriate" will not be issued a building permit. Id. Additionally, an explicit purpose of the Village Zoning Code is "[t]o protect property values and the enjoyment of property rights by minimizing and reducing conflicts among various land uses through the application of regulation designed to assure harmonious relationships among land uses...." Art. I,§100, Village Code. Applications to the Village Council are also subject to a harmony evaluation. The Village Council must consider "the appearance of the proposed building and the development of the site with respect to its harmony with existing and prospective development in the neighborhood....'" Art. VI §603, Village Code. 6 The New Zoning Ordinance did not inordinately burden the Subject Properties because the proposed development on the Subject Properties was always (and still is) restricted by the requirement that it be harmonious with existing development in the neighborhoods even before the New Zoning Ordinance was enacted. A government action "inordinately burdens" real property if it has directly restricted or limited the use of real property such that the property owner is permanently unable to attain the reasonable, investment -backed expectation for the existing use of the real property or a vested right to a specific use of the real property with respect to the real property as a whole, or that the property owner is left with existing or vested uses that are unreasonable such that the property owner bears permanently a disproportionate share of a burden imposed for the good of the public, which in fairness should be borne by the public at large. §70.001(3)(e), Fla. Stat. A. Bluenest Did Not Have A Reasonable Expectation That The Subject Properties Could Be Developed As Proposed. For an `'investment -backed expectation" to be "reasonable," generally, it must be objectively reasonable. Brevard Cnty. v. Waters Mark Dev. Enterprises, LC, 350 So. 3d 395, 399 (Fla. 5th DCA 2022). Where restrictions other than the zoning code prohibit a landowner's proposed development, an owner does not have "reasonable" investment -backed expectation in the proposed development. Id. As discussed in more detail in Section 1 above, because the Proposed Development on the Subject Properties were not harmonious with the respective properties' neighborhoods, Bluenest did not have a reasonable expectation in the Proposed Development, and its Bert Harris Act claim must fail. B. Bluenest Did Not Have A Vested Right To The Proposed Use Of The Subject Properties. A vested right, as defined in the Act, can be established by applying principles of equitable estoppel or substantive due process. §70.001(3)(a), Fla. Stat. Equitable estoppel should be applied against a government entity "only in rare instances and under exceptional circumstances." Monroe County v. Hemisphere Equity Realty, Inc., 634 So. 2d 745, 747 (Fla. 3d DCA 1994). To show equitable estoppel that would create a vested right, the Claimant must show that it "(1) in good faith, (2) [relying] on some act or omission of the government, (3) has made such a substantial change in position or has incurred such extensive obligations and expenses, so that it would be highly inequitable and unjust to destroy the right he acquired." City of Hollywood Beach Hotel Co. v. City of Hollywood, 329 So. 2d 10, 17 (Fla. 1976). Bluenest has not provided any facts that would establish a vested right. To the contrary, its architects proclaim to have worked extensively in the Village and were well aware of the requirement that the Proposed Development be harmonious with the respective existing neighborhoods. Their plans included an analysis of the character of neighboring properties. Bluenest cannot claim to have relied on any act or omission by the Village to incur expenses for the Proposed Development where their own professionals acknowledged the need for harmony with neighboring properties, and the Previous Code was explicit about this requirement. Accordingly, Bluenest fails to establish a vested right in the Proposed Development. C. Bluenest Is Left With Reasonable And Valuable Uses Of The Subject Properties. Bluenest cannot show that the Subject Properties are inordinately burdened by claiming that the remaining uses after enactment of the New Zoning Ordinance are "unreasonable such that the [Bluenest] bears permanently a disproportionate share of a burden imposed for the good of the public, which in fairness should be borne by the public at large." §70.001(3)(e), Fla. Stat. After enactment of the New Zoning Ordinance, Bluenest is still entitled to develop its property with a two-story, single family residence, exactly as before the enactment of the New Zoning Ordinance. Moreover, Bluenest's own appraiser concludes that after the enactment of the New Zoning Ordinance, the 9305 Property is still worth a substantial amount of money once developed - $3,950,000. Similarly, Bluenest's appraiser concludes that after enactment of the New Zoning Ordinance, the 78 Property is worth $6.6 million. Given the substantial remaining value that both properties have, Bluenest cannot claim that the New Zoning Ordinance inordinately burdened the Subject Properties. 4. BLUENEST HAS NOT PROVIDED THE REQUIRED APPRAISAL THAT SUPPORTS ITS CLAIM AND DEMONSTRATES THE LOSS IN FAIR MARKET VALUE TO THE REAL PROPERTY. Failure to comply with the procedural requirements of the Bert Harris Act will require dismissal of any claim filed in court. Wendler v. Village of St. Augustine, 108 So. 3d 1141, 1144- 45 (Fla. 5th DCA 2013). The Act waives sovereign immunity, thus its provisions, including the presuit requirements, must be strictly constructed in favor of the government. Maynard v. State, Dept. of Corr., 864 So. 2d 1232, 1234 (Fla. 1st DCA 2004) (requiring strict construction and application of the presuit notice requirements in section 768.28, Florida Statutes, which waives sovereign immunity). The Bert Harris Act requires a property owner, prior to filing suit, to provide a notice of claim to the government accompanied by "a written appraisal report ... that supports the claim and demonstrates the loss in fair market value to the real property." Failure to comply with the appraisal requirement will bar any action under the Act. Osceola County v. Best Diversified, 936 So. 2d 55, 59 n.5 (Fla. 5th DCA 2006) (concluding that an "appraisal" attached to a claim letter which was not a "bona fide, valid appraisal" prevented a finding of liability against a County); Sosa v. West Palm Beach, 762 So. 2d 981, 981 (Fla. 4th DCA 2000) (dismissing suit where plaintiff failed to present any appraisal supporting his claim prior to bringing suit). The purpose of the Act's appraisal requirements is to provide the governmental entity a "means by which to evaluate the potential claim for the purpose of making a settlement offer." Turkali v. City of Safety Harbor, 93 So. 3d 493, 495 (Fla. 2d DCA 2012). Without a credible and proper appraisal, this essential and legally required presuit evaluation cannot occur. Bluenest provided four appraisals in support of its claim: l . An appraisal of the purported value of the 9305 Property before the enactment of the New Zoning Ordinance ("9305 Pre -Ordinance Appraisal"); 2. An appraisal of the purported value of the 9305 Property after the enactment of the New Zoning Ordinance ("9305 Post -Ordinance Appraisal"); 3. An appraisal of the purported value of the 78 Property before the enactment of the New Zoning Ordinance (" 78 Pre -Ordinance Appraisal"); 4. An appraisal of the purported value of the 78 Property after the enactment of the New Zoning Ordinance ("78 Post -Ordinance Appraisal"); The difference between the pre -ordinance appraisal and the post -ordinance appraisal is meant to demonstrates the "loss in fair market value" caused by the enactment of the New Zoning Ordinance. Here, Bluenest claims that the New Zoning Ordinance limited the square footage of the residence that could be constructed on each property (on the 9350 Property by 739 square feet, and on the 78 Property by 716 square feet). The four appraisals do not meet the requirements of the Act for a number of reasons. First, the appraisals fail to show the loss in fair market value of either property because they value the Subject Properties as if they had already been developed with new residences. But the Subject Properties are not developed as of the date of the claim. Second, the appraisals are so arbitrary and flawed, that they cannot be said to "support the claim" or "demonstrate the loss in fair market value" of the Subject Properties. Third, the appraisals violate USPAP calling into question their usefulness in supporting the Bert Harris Act claim and their validity. Finaly, the appraiser fails to do a highest and best use analysis, thus appraisal does not support the Bert Harris Act claim as required by the Act. A. The Appraisals Fail To Show The Loss In Fair Market Value Of The Subject Properties Because They Do Not Analyze The Value Of The Properties Prior To Enactment Of The New Zoning Ordinance And After Enactment. An appraisal provided with a presuit notice under the Act is required to "demonstrate[ ] the loss in fair market value to the real property." §70.001(4)(a), Fla. The loss in fair market value is determined "by calculating the difference in the fair market value of the real property, as it existed at the time of the governmental action at issue, as if the owner had the ability to attain the reasonable investment backed expectation ...[and] the fair market value of the real property, as it existed at the time of the governmental action at issue, as inordinately burdened. . . ." §70.001(6)(b), Fla. Stat. (emphasis added); see also DHBHAtl. L.L.C. v. City of Delray Beach, 334 So. 3d 332, 337 (Fla. 4th DCA 2022) ("Harris Act's plain language establishes that the determination of the fair market value of the property must be measured at the time when the governmental action first affected the property.... No claim for compensation under the Harris Act could have been accurately determined using an appraisal value from 2015 —three years before the governmental action was in effect."); Turkali, 93 So. 3d at 495 (finding that the presuit notice was deficient because the appraise failed to provide an opinion of value of the property as it existed before and after enactment of the new use restrictions). The government action at issue is the enactment of the New Zoning Ordinance. At the time of the enactment of the New Zoning Ordinance, the 9305 Property was improved with a 2,499 SF single family residence built in the 1940's that Bluenest intended to demolish in order to construct a new, larger single-family residence. Yet, the appraiser values the 9305 Property before the New Zoning Ordinance is enacted as if it was improved with a 5,054 SF new, single-family home. The appraiser values the 9305 Property after the enactment of the New Zoning Ordinance as if it was improved with a 4,036 SF new, single-family home. The appraisals, therefore, unequivocally fail to show the loss in fair market value as of the date of the governmental action — i.e. the enactment of the New Zoning Ordinance. This is particularly egregious in this case because the higher the property values, the greater the damage figure. Thus, assessing the damage as if future, valuable improvements are already in place improperly inflates the damage figure. For example, Bluenest purchased the 9305 Property for $950,000 in October 2023. If Bluenest's damage figure is assumed to be correct, the New Zoning Ordinance reduced the 9305 Property value by 34%. As improved with a new residence (which the 9305 Property was not improved with a new residence as of the date of the New Zoning Ordinance or even as of the date of this claim), the 34% reduction leads to a $2,050,000 damage. If the property were instead assessed based on its value for which it was purchased ($950,000), a 34% reduction in value would result in a $324,583 damage. The appraisal, therefore, fails to show the loss in fair market value of the actual property that exists as of the date of the government action. As a result, it does not meet the requirements of the Act as it provides a grossly and improperly inflated damage figure. The damage claim is so exorbitant and out of line with reality that it would entirely compensate the property owner for the purchase price of the property. In other words, the Village could essentially outrightly purchase the property for less than the purported damage caused by the New Zoning Ordinance. This is not proper or credible. Moreover, it fails to consider that with a smaller residence come reduced construction costs, which may ultimately make the difference between the before value and the after value smaller. Given that the appraisal does not meet the requirements of the Act, Bluenest cannot proceed with its claim as presented. A similar error is present with the appraisals for the 78 Property. At the time of the enactment of the New Zoning Ordinance, the 78 Property was improved with a 2,155 SF single family residence that was built in the 1940's with additions in 1978. Bluenest intended to demolish the existing residence in order to construct a new, larger single-family residence. Yet, the appraiser values the 78 Property before the New Zoning Ordinance is enacted as if it was already improved with a 6,404 SF new, single-family home. The appraiser values the 78 Property after the enactment of the New Zoning Ordinance as if it was already improved with a 5,688 SF new, single-family home. The appraisals, therefore, unequivocally fails to show the loss in fair market value as of the date of the governmental action — i.e. the enactment of the New Zoning Ordinance. This error in the appraisal cannot be corrected after a lawsuit is filed and would lead to automatic dismissal of any claim filed by Bluenest in Court. See DHBH Atlantic, 334 So. 3d at 338. N B. The Appraisals Are So Arbitrary And Flawed That They Do Not Support The Claim Or Demonstrate The Loss In Fair Market Value. Bluenest's appraiser uses a comparable sales approach to value the property with future hypothetical improvements in place (i.e. large, new residences). In the comparable sales approach, the appraiser finds similar properties that bought and sold in the market and may adjust the sales for differences that make the sales more or less valuable than the property being appraised. Quantitative adjustment (meaning adjustments of a particular dollar amount) require market support to be credible. See Walters v. State Road Dept., 239 So. 2d 878, 881 (Fla. 1 st DCA 1970). Bluenest's appraiser makes a number of quantitative adjustment to the comparable sales used in all four appraisals, for which he provides no market support (or even a credible explanation). The unsupported, unexplained adjustments make the appraisal arbitrary, unreliable, and wholly inadequate to demonstrate the loss in fair market value to the Subject Properties: a. The only adjustment that is consistently made to the comparable sale values throughout all four appraisals is a $250 per square foot of building size adjustment. Sales containing larger residences than the hypothetical residences on the Subject Properties were adjusted downward (as they are considered more valuable) by $250 per square foot. Sales that contain smaller residences than the hypothetical residences on the Subject Properties are adjusted upward by $250 per square foot. Although this is the most benign of the appraiser's adjustment because it is at least consistently applied, the appraiser still provides no market support to justify this adjustment. b. The appraiser makes adjustments for properties that are listings as opposed to sales because the listings are not a completed market transaction (in other words, it is unclear what the final sale price will be). However, he does not make the adjustments consistently. By way of example, the listing for 1202 NE 93rd Street (used in the Pre - Ordinance Appraisals for both of the Subject Properties) is adjusted downward by $349,000 for being a listing. The appraiser provides no market support for the adjustment. Similarly, the listing for 441 Grand Concourse (Comp. No. 4 in the 9305 Post -Ordinance Appraisal) is adjusted downward $282,500 without any explanation or market support. The adjustments are different percentages of the listed sale price, so it is unclear how the appraiser arrived at these numbers. On the other hand, the appraiser makes no adjustment for the listing at 1275 NE 93`d Street (used in both the 78 Pre- and Post- Ordinance Appraisals), thus, he does not account for this property being a listing. C. The appraiser only sometimes adjusts for differences in land size. By way of example, the appraiser adjusts 1071 NE 95th Street (Comp. No. 3 in the 9305 Pre - Ordinance Appraisal) downward by $50,000 because the land size is larger than that of the 9305 Property by 7,525 square feet. In other words, in the adjustment, the appraiser communicates his belief that the comparable sale is less valuable because it has more land than the 9305 Property. Yet, the appraiser makes no upward adjustment to 1208 NE 99"' Street (Comp. No. 2 in the 9305 Post -Ordinance Appraisal), which is 1,425 square feet smaller than the 9305 Property. If the same principle were applied to 1208 NE 991h Street as was applied to 1071 NE 951h Street, then a $7 per square foot upward adjustment would In be warranted. None is made, which depresses the range of sales conveniently in favor of diminishing the post -ordinance value of the 9305 Property. While the Village looked for a plausible explanation regarding this discrepancy none was found. Comparable properties used to value the 78 Property were adjusted for a similar difference in square footage as the aforementioned. Specifically, the appraiser negatively adjusted 1275 NE 93rd Street (Comp. No. 2 in the 78 Pre -Ordinance Appraisal and Comp. No. 3 in the 78 Post -Ordinance Appraisal) by $250,000 for being 1,400 SF smaller than the subject (the opposite of what was done with Comp. Sale No. 3 in the 9305 Post -Ordinance Condition Appraisal, which was adjusted downward for being larger than the subject). There is no rhyme, reason, or explanation for such arbitrary decisions that ultimately affect the Village's range of exposure. d. In addition to the lack of consistency in making adjustments for land size, the appraiser's unit amounts for the price adjustments for land size are similarly scattered, arbitrary, and unexplained. When viewing all the comparable sales used throughout all four appraisals, the unit adjustments for land size ranged from $0 per square foot ("PSF") to $179 PSF without explanation. Even when considering the appraisals for each of the Subject Properties separately, the ranges are inexplicable and arbitrary. For the 9305 Appraisals, the adjustments range from $0 PSF to $52 PSF, and for the 78 Appraisals, the adjustments range from $0 PSF (with an up to 5,000 SF difference in size) to $179 PSF. There is no possible logical or market -based explanation for this lack of consistency. e. The appraiser's adjustments for differences in the number of rooms and bathrooms are similarly scattered and arbitrary. As no explanation is provided, the Village has no way to assess the credibility of the adjustments or normalize the impact on the sales. By way of example, the appraiser makes adjustments for number of rooms and number of bathrooms in the 78 Appraisals but does not adjust for similar differences in the 9305 Appraisals. Even within the 78 Appraisals, the adjustments are anything but consistent. For example, for the 78 Appraisals, the appraiser uses 1202 NE 93`d Court as a comparable for both the before and after condition. In the pre -ordinance condition, the appraiser adjusts the sale upward for the number of bathrooms, even though the number only exceeds the subject by one, half -bathroom. The adjustment amounts to $12,500 per half bathroom. A similar adjustment is not made in the post -ordinance condition even though the differential in bathrooms is the same. f. The appraiser adjusts the comparable sales for differences in the square footage of the residences, number of rooms and bathrooms, and lot sizes. Larger residences result in an increased price per square foot (as the appraiser deems them more valuable). A greater number of rooms and/or bathrooms result in an increased price. Larger lots, however, result in a decreased price. These adjustments are not supported by his own comparable sales, which instead contradict the conclusion that any adjustments should be made. By way of example, in the 9305 Appraisals one of the second highest sales (Post - Ordinance Comp. Sale No. 3), is also one of the smallest residences with the fewest rooms and the largest lot size. Similarly, with the 78 Appraisals, the larger buildings sold for some of the lowest prices, and the larger lots fell somewhere in the middle or upper end of the 11 range. Given the contradiction to the proposed adjustments that are shown by the appraiser's owns sales, there is no market support for the adjustments. g. The appraiser adjusts the comparable sales for smaller residences and for having fewer rooms. However, there is no logical explanation for the appraiser's adjustments for both as logic dictates that there is likely overlap between the two. This duplicative negative adjustment clearly falsely inflates the damage figure since Bluenest's claim is entirely based on the fact that the residences it can build on the Subject Properties are smaller because of the New Zoning Ordinance. h. The adjustments for building conditions are similarly arbitrary and inconsistent. By way of example, the comparable sale located at 489 NE 95`h Street is used in the 78 Post -Ordinance Appraisal (Comp. Sale No. 2) and in the 9305 Pre -Ordinance Appraisal (Comp. Sale No. 2). In the former, the appraiser adjusts the sale upward by $250,000 for the building condition. In the latter, he does not although the same condition exists. While this particular lack of adjustment may work against the property owner, it is the overall lack of consistency and explanation that makes the adjustments overwhelmingly unreliable thus causing the appraisal to lack reliability and usefulness. There are also blatant errors in the appraisals. By way of example, for the pre -ordinance value of the 78 Property, the appraiser uses 1202 NE 93`d Street as Comparable Sale No. 3. For the post -ordinance value of the 78 Property, the appraiser uses the same sale as Comp. Sale No. 4 yet misreports the square footage of the building such that in the before value the price per square foot before adjustments is reported as nearly $100 more than in the post -ordinance scenario. This error skews the range of sales such that it conveniently diminishes the potential price per square foot of the property after the New Zoning Ordinance was enacted with no market support. The appraiser also concludes outside (and of course below) his own adjusted and unadjusted ranges for the post -ordinance value of the 9305 Property, making it clear that the 9305 Property Post -Ordinance Appraisal conclusion does not reflect market value. The range of sales in the post -ordinance appraisal, as adjusted by the appraiser, is $939 - $1,424. Yet, the appraiser concludes the property is only worth $917 per square foot. Had the appraiser used the lowest end of his own market range, the damage figure would be $700,000 less. The non -market conclusion of value creates a greater gap between the pre -ordinance and post -ordinance value of the 9305 Property than cannot be justified by the market even if one were to give any credence to the appraisers unsupported adjustments. Finally, and most egregiously, the appraiser comes to a different and, again, unsupported conclusion of the per square foot value of the Subject Properties in the pre -ordinance condition versus the Subject Properties in the post -ordinance condition, which seems to be only for purposes of increasing the damage claim as no other support is provided for the value conclusion. Each property will be addressed in turn: 9305 NE 9 Avenue Appraisals Before New Zoning Ordinance PSF/ Building Pre -Adjustment Comp. Sales Range: $1,223 - $1,481 Post -Adjustment Comp. Sales Range: $1,167 - $1,424 Conclusion of Unit Price: $1,189 12 TOTAL VALUE BASED ON UNIT PRICE 1 $6,000,000 After New Zoning Ordinance PSF/ Building Pre -Adjustment Comp. Sales Range: $994 - $1,318 Post -Adjustment Comp. Sales Range: $939 - $1,424 Conclusion of Unit Price: $917 TOTAL VALUE BASED ON UNIT PRICE $3,950,000 Based on the foregoing, the appraiser has concluded that the same land in the same location, due to a loss of 739 square feet residential building, (which he only adjusts for in the comparable sale adjustments at $250 per square foot) results in a $2 million plus reduction in value. Based on the appraiser's own adjustments, this cannot be true. The appraiser adjusts the comparable sales downward at a rate of $250 per square foot. If applied to the reduction is square footage in the post -ordinance condition, this should only result in a $184,750 reduction in value for the 9305 Property. Similarly, if we were to account for the loss in bathrooms and rooms due to the reduction in the square footage (which likely is not warranted given the loss in square footage has already been valued), at a rate of $50,000 per room and $50,000 per bathroom, that would only result in an additional $200,000 in damages. If added to the reduction for square footage (assuming arguendo this double counting is appropriate), the total damage would be $384,750 — not $2 million. The very appraisal upon which Bluenest is relying belies the appraiser's unwarranted and unsupportable over -statement of damages. The appraisal is so flawed and the appraiser is clearly compromised to such a degree that the appraisal cannot be said to demonstrate the loss in fair market value to the property if there even is a market -based, measurable loss. 78 NE 98" Street Before New Zoning Ordinance PSF/ Building Pre -Adjustment Comp. Sales Range: $1,018 - $1,481 Post -Adjustment Comp. Sales Range: $932 - $1,498 Conclusion of Unit Price: $1,124 TOTAL VALUE BASED ON UNIT PRICE $7,200,000 After New Zoning Ordinance PSF/ Building Pre -Adjustment Comp. Sales Range: $1,018 - $1,481 Post -Adjustment Comp. Sales Range: $909 - $1,440 Conclusion of Unit Price: $1,160 TOTAL VALUE BASED ON UNIT PRICE $6,600,000 Again, the appraiser would have us believe that 716 square foot reduction in building and no reduction in rooms or bathrooms will result in a $600,000 difference in value. This is not credible based on the appraiser's own adjustments. Applying the appraiser's own adjustments, the reduction in square footage would only lead to a mere $179,000 damage — not a $600,000 damage. Due to the appraiser's complete lack of market support and credibility and his biased and contradictory opinions, Bluenest has entirely failed to provide the requisite presuit appraisal that demonstrates the true loss in fair market value to the 78 Property. 13 For all the aforementioned reasons, the appraisal fails to comply with the clear statutory requirement in the Act that it "support the claim" and "demonstrate the loss in fair market value to the real property." §70.001(4)(a), Fla. Stat. C. The Appraisals Violate the Uniform Standards of Professional Appraisal Practice ("USPAP") Calling Into Question Their Usefulness In Supporting The Bert Harris Act Claim And Their Validity. The written appraisals provided in support of the Bert Harris Act claim violate USPAP because they are restricted appraisals that are not intended solely for the client's use. The appraiser identifies his client as Bluenest Development, which is not even the property owner. The appraisal explicitly says that it is a "Restricted Appraisal" "for the use of the client only." This restriction is explicitly imposed because any other use of a Restricted Appraisal violates USPAP, which the appraiser is bound to follow. USPAP Standard 2-2 states that all appraisal reports must either be an "Appraisal Report" or a "Restricted Appraisal Report," as those terms are defined in USPAP. The comment for Standard 2-2 requires that "[w]hen the intended users include parties other than the client, an Appraisal Report must be provided." Whereas, a "Restricted Appraisal Report" may be provided if the intended user is limited to the client. Because the appraisal was intended to support a Bert Harris Act claim, which necessarily includes use by a third -party that is not the client, the appraisal violates USPAP. In fact, it seems that the use was not disclosed to the appraiser at all. The appraiser reports that the Intended Use for each appraisal "is for the lender/client to evaluate the property that is the subject of this appraisal for a mortgage finance transaction." D. Bluenest's Appraisals Do Not Support Its Claim Because They Fail To Analyze Whether The Proposed Development Is A Legally Permissible Use Prior To The Enactment Of The New Zoning Ordinance. In order to seek compensation under the Act, Bluenest must show that the Proposed Development was an "existing use" as defined by the Act (see § 1 above) prior to the enactment of the New Zoning Ordinance. The Act's definition of "existing use" is based on the concept of highest and best use of land that is used in appraisals. See David L. Powell et. al., A Measured Step to Protect Private Property Rights, 23 Fla. St. U.L. Rev. 255, 267 (1995). In Florida, all appraisers must comply with the USPAP, Fla. Admin. Code R. 61J1-9.001 (2017), and USPAP requires that an appraiser develop a highest and best use opinion when such an opinion is "necessary for credible assignment results." USPAP, Standards Rule 1-3(b). Therefore, it stands to reason that the Act requires an appraisal in part to "support the claim" because an appraisal should analyze highest and best use and, as a result, the validity of a claim of "existing use." Bluenest's appraisal entirely fails to provide a highest and best use analysis and, therefore, does not "support the claim." A highest and best use analysis identifies the "reasonably probable and legal use of [property] that is legally permissible, physically possible, appropriately supported, financially feasible, and that results in the highest value." S.-W. City Sch. Bd of'Educ. v. Franklin Cnty. Bd. of Revision, 128 N.E.3d 757, 770 (Ohio Ct. App. 2018). For a use to constitute a highest and best use it must be legally permissible. To analyze the value of the Subject Properties before the New Zoning Ordinance was enacted, Bluenest's appraiser assumes, without explanation that the Proposed Development was legally permissible because it complies with the minimum defined standards in the Previous Code. The appraiser entirely ignores the fact that the Previous Code also 14 required developments to be harmonious with the surrounding neighborhood, providing that the Board, when acting on a site plan shall make requirements with respect to building design "including setbacks ... as will assure a harmonious relation between the uses to which the site plan applies and the existing and prospective residential and other developments in the vicinity," Village Code, App. A, Art. VI §604. The plain language of this provision shows that mere compliance with the defined minimum requirements in the Previous Code is not sufficient to obtain approval of the Proposed Development. The appraiser entirely ignores this provision and fails to analyze whether the Proposed Development is legally permissible under this provision of the Previous Code. Rather he assumes, without explanation, that it is. Because the appraiser fails to conduct a highest and best use analysis, the appraisal fails to "support the claim" as required by the Act. 5. THE NEW ZONING ORDINANCE HAS NOT BEEN APPLIED TO THE SUBJECT PROPERTIES AS DEFINED BY THE ACT. The Act "provides relief... when a new law, rule, regulation, or ordinance of the state or political entity in the state, as applied, unfairly affects real property." §70.001(1), Fla. Stat. A law or regulation under the Act is "first applied" when one of the following three things occurs, none of which have occurred here: 1. Upon enactment of the law the government entity sends notice to the affected property owners that the law or regulation may impact the property owner's existing property rights, and that the property owner may have only 1 year after receipt of the notice to pursue any rights established in this section; 2. If the property owner notifies the head of the governmental entity in writing via certified mail or email that the property owner deems the impact of the law or regulation on the property owner's real property to be clear and unequivocal in its terms and, as such, restrictive of uses allowed on the property before the enactment, and the government entity is given 45 days after receipt of the notice to respond in writing to describe the limitations imposed on the property by the law or regulation; or 3. Where there is a formal denial of a written request for development or variance. §70.001 (1 1)(a), Fla. Stat. As such, Bluenest cannot make a claim under the Act because the New Zoning Ordinance has not been applied, and the Act only provides relief when a new law is applied. The Act is strictly construed in favor of the government because it waives sovereign immunity. See generally Bair v. City of Clearwater, 196 So. 3d 577, 582 (Fla. 2d DCA 2016) ("[S]tatutory waivers of sovereign immunity, such as the waiver in the [Harris] Act, must be strictly construed, with any ambiguity concerning the scope of the Act resolved in favor of the government against the claimant."). As such, Bluenest cannot make a claim until it follows the proper procedure. SETTLEMENT OFFER Section 70.001(4)(c), Florida Statutes, requires the Village to make a written settlement offer during the 90-day notice period. That period began on November 27, 2024 and expires on February 25, 2025. Subsections (1)-(11) of the Act provide eleven options for settlement. Pursuant to subsection (11), the Village hereby offers to take the following action: 15 No changes to its actions, except that Bluenest's application fees for the 9305 Property Application and the 78 Property Application will be refunded for a total refund of $3,000. Bluenest must provide written notice to the Village of the option it will elect by sending the notice via electronic mail to Alicia Gonzalez, Esq., Weiss Serota Helfman Cole & Bierman, P.L., 200 E. Broward Blvd., Suite 1900, Fort Lauderdale, FL 33301. The Village expressly reserves the right to revisit the issue of settlement in the future. AG:tj Enclosures 16 Sincerely, /4� Alicia Gonzalez, Esq. 9 / 3 4 / s ƒ % } Construction > $ 2 » \ \ j / 0 \ f \ Oq k ! I ( ¥ ƒ z / ƒ > ] J & / 0 7 g % ) 2 § J [ ƒ / y G 5 ® R � _ ) / ` , ƒ M { & @ 7 z $ 2 , } I / S \ 7 § & 3 - J $ _ } ] \ , , } } - , & & / @ £ e = E / ° & a ® ® m E m\ s\ ^ % 3 m\ d f 2/ 2 f / s CD§^ £ \ s m \ f I & Z m ; a zrD & g .. e { _ f % \ _ / Q- UO \ \ ) � 0 � ? § R 0 ) ( 0 z ] a N W N In In 61 V OD N O j N N N W N Ul N Ol N CO W O W (n In Ln (P In Ln In In i (D N N� W N� fD N N ' (D J — O — (D O D _, O N -^ N W D N f O Cn N W fD W O -^ rD ( W -n In O N O U, In rD In U, (^ C)( CD(^ LP rD (D O (rD C:)� C)(^ CD(^ O O � O O O O Ul O O O O O O O O O O O O O O O O O O O O O O O O O O O O O n c O- n c CT n c 9 n c 6 n C O' n C CT n� n c O- n n c O- n n C CT n n C 6 n n C 6 n n c O' n�n� n c S n c O- n c o- n C CT n c 6 Masonry O 7 V < rt v !�D c - A W Q N X N N 3 Q O O fD 0 7 N o Q (D _. v Q n S °° c ^ 0 0'Q n ° [rD �. Iz c n Q° N N ci O1 n °' = D Q z fp C �< 3° rr — Q o Q -' D a o O Q m O w 0 v c (D m N O S — to Oq a6 3 0' UG ° Q ° rD g o v -0 o Ao C) �' Q Q as is v 3 a v :3OG 3 N N O (ID in CD n w 04 (D n N N In Q Q � c6 N !n �n O O c< Q ,< �^ (D C < to O rD �, O ° N O O N 03G O p �n — 3 3 0'Q �* O O CT N O 3 7 N (D N O_ N ET - n �' 6 c v(Di vi vi X n Q OV N v <. rD S (p N �n O -�' Q rD ^ n rD -O 3 0'G in (D O ID rD vi 3 Q Cr p- n A O -0 O W 0 c (D3 n < -p - n v < O O O -o N w O 3 Q M n C 3 D 3 �, n O rD n c = 0 rD Ln fD O C v N 3 S n w 3 O w n (D n C (p (D n Q O C to N m (D N 3 N vi (D S v `< pq T O `< O N (p O 3 M o � (D ^ A v 3 3 a zr a 3 v' ram-' c � v (0DD o o 3( fD m Q� n o Q o 3 ro OQ N M 3 0'4 N rD3 O O. N fD fD N C O �' OQ Cr N 3 Q D 3 n _O (DrD in 3 D,3 `G c S to 3 'O r3r O O rD 3 9i .c-' tf Q 0 Q 3 N I 07 O r7 S rD 3 Q n 0 -o 3 3 S rD 3 O 3 S D Q v 3 Q O 3 In O J In O Z p- C y n n O r. 0 y 0 _0 S a C o m n _ 0- C T 0 O- `< rD � m rD �� O 3 3 - 3 -_^ o n -p q v 3 - � o 3 rD n N v � Q -ni o Q � (SD r(D-r 0—p_ mc n_ n O ID 0-2 Q O m 0- rt S rDO 0- O rr O Q rD 3 (D O 0 3 cn 3' ram-' S. rn+ (D p_- N 3 °° D v� p 3 Q c 3 N 3 O- j- O C 3 S (D WO OQ 3 LA O N C O)CI N 7' ,ti Q w 0 3 N N (D x O 3 0 ,y W Ln DO 3 (D v CT c (D cu O Q � U O N O 0 �' 0 N m 4 a � ° (D N Q to in (D S N =�, 3 rt ;. fD N �p (D 3 r S O rt rN-r v 3 OQ ^ (n N X ram' S (D 3 c (D tNii N rt N 3 �< In N :3 LA _^ °_ N S C fD 3 O 3 O- (D Q. 03Q 3CTS S n -0O rD 3 S (D S M O „ S N OT S < Q S !D Q o N O O Q ° O 3 rD n S o Q _rD OC rD _ = N 0 3 3 3 0 rD 0 O ED 03 N C 3 O (A N O 3 3 N S (D C 3 N ^�' 3 N ° S O T 3 Ul — rD rD O Q S 0mwnw S = N N 'O !n rD rD X 0 O (D O r-"r O S CD 0 ^ 3 3 N rD O Q Ln to CS -n O rD to Q -0 N to cn W W to VI W rD n to -0 00 ° to rt N — 9r S -0 0 ,�'y Cl T 0 (D 3 C ^ N j N o to -0 N c ^ N N n p (D 15 n' 3 3 O rD (D p O fD (D 3 CT 3 9 (D (D O 3 O N 3 -n O (p M CA c 3 QQ C O 3 p O C O T. — j T. c — �, 3 Q n (Sp 3 S fD O `Y -0 Q 3 to O O ID N (D N (D N o m OO 3 m (D CT (D O 3 N O 0 p S j ° J O 3 O O OS _O o O 3 O S 3 3 :--. N �___OIT o— _O o 3 7t, X S ^ (Oi S °°-0_N (D (D 33 CU M c 3 (D 0 N Q SL � �(,rLDn 0-n O N 0 n Ol C n N (D 7 V, w 3 OO 3 3 N O rr_ N S Q (n (D Q C 0 O O o N < Q O `< `� N to `G v v N o `G n No -. Q 3 3 (D Q Q o O 3 rD Q fD 3 v 3 — N v S N ^ O v Q m `< (D `< o OL (D N iZ N cn O CD N N fD T r 0 m 0 O d j N 0 (D U, w N 6 O- ___--_-_-__. ____.-____ ._ _______..__..__-.. _ -- __ -- - - -_ - _______ CD C 6 CTl N 7 � � N r L rD p OrD S Q 0 -" Q 3 N O Q O (D 7 n N `< S On Q n N N n O Q c O -O N 1 OQ n Q (D Q Q N w ID `< _. Q to 0 N S c In O 3 v O = S 3 rt rD Q N OQ n rD 0- Q -6 -I n O 01 -p S — p G In In v Q O N S OQ n z n rD d S o n tD O n w = O � °O r-r — o �_ 7 O 3 m O 3 1p Q ,ten (D 3 n` rD < c o v m O N O f-r f-i (p N rD (D N n - In (D O Q. N Vi N < (D 3 N C O n O �. G ro N O '-' S m rD O OQ O -p Q O (D n O S O N S rr c 7 O (D Q (D 7 rr Q S n -p 7 O J c !� 6 7 O -O N 7 vi N O i^ �` O `vOi ? Q O n Q N 77 (n (D �. N rD C 00 Q m O N. v 7 N p to V1 O O O N in N pFU' Q Q N n (D N Q cn to to N O -O O 6 0- O Q V) o- T N -O 7 -O Vl On (D N n N n Q- 7 O c c 3 p N c O p rD O O O rSD O. n N n fl- tOn O tni c Q �` Q O < O O v N Oq rD 73 s ,fir o ° o (D N Q IDfD _Q s ,�-' D rt n. � ^ a ^ a < N aQ o� ^ v v v �o o o O G (D rD r rr Q (D Q °v° °° — `D Q m OQ o 7 vi (SD W Q S !D S Q (D to to O In -O O S 6 O -^ O O '"* O c Q Vl to S m (D in Q -p N -0 in to v to _ N _ Qo,N O O Q 0 S O N c. O n rD 0 N n (D rD O O' v c Q =n Q N -O O < - In n rD rD (D C Q n N — = (D S OS 6 N (D cn n N n tnU O ,tin o- - c - _(Dm O n � fQD 7 Q rD v C 7 ON S O 7 O '-r O 7 c O n 3 v Q N O Q (D Q ID y, (D - rD �, O (gyp O rD ' W Q v ZrrD O, O O in O (D S O S 'O O0 'O -O O S 6 O rD — O ] _ O - S in -p O_ _C ._ r�l O O 7 N '6 c -• (D U c n S 9i c n c n c C -. S In (D .�* < N Q -p Q cn rD n (D S = S v Q (D Ln p c _ �, Q N -O O Q n rD rD O O- O' N O v O O n -� O S O N S c -6 _Q 7 O' 7 * O- w n O �` �n Oo Q �. `< v (D OQ OQ R (D 7 Q (D Q N _ = Q p N Q N O Q n rD Q in N 0OQ �. S O N N O (LSD W Q N 3 Lq rD O �. OQ `G (D 7 -o c n n 7 S CD O 7 r2 c S v N 3 rD O M p Q n O (QD O Q (6D p_O O O 7 Q (D Q S rD v `< O S �. S Q N 9i N O Q N O p Q .r-"r Q 3 v O iD n `Y O O n v am M O o rD c O MDM Di v N v3i 0- 0 O O s 3 g, a m aoa s 0- o s 3 a o v o N �. p N .�-' (D 2 � N O (D S 2 Q rD rt Co c N O-__.__- __ _..___- _ __ N (TI D) ' 7 � N A N 6 W O_ N - N (D S -O 7 N 3 c a r D - (D O rr rD N O n = n C O (D 3 �• Q 3 7• O 0'O O N O O S 7�- bQ N �_ tD S v�i `� v3i O N O S N N �< O M (D S (D N (D �- O' 7 7 O C to w N C O (D N N ^ m (N-r O LA N V N CO S O (D N N (Q D T1 r — n V1 (p -O 0' o N O S N S -O C O -O N � 07 a N O O v 5. O< O (D -O N v 7 o- n ZrO- a Oq G 7 n CD In -O 6 w v S N In N O_ In In In n O d Q N - O o , m w n N n .--r. < Ei D_N _O Q. N N n S - S S n 00 ID N O 7 < OQ S (D O_ O < (D 3 0'Q 7 S O O O (D QQ < J " EA n 7 Q N (n C -O r4 3 N N -6 n `G N N n (n In O' D N 7 O N O n p O N 7 (D X O N S S O O N p 3 p (D S O n S S O O <D o 3 c ° D- w W M 3 n v rD Z n � n <D Q v o o a o a n m a Q - (D ,-' f* - n 'p tD (D 01 (D M (D N tD (D N ID . OU r�-r d N OQ 4u 'r,,' O �O O �" to O �p O O fl- 3 O O pip 7 OHO O 7 N O z" 3 �n Q. !D O .G O 3 - (D S N v S v (D N N O (D (D N rD rD O to to 6 (D 7 z Cn `G 3 O. 3 (�D N o �.^ 7 W y -p in v T no G to Q 7 7 N O rD N O � D c I (D n m (D (D m n 3 C (D 7 + flJ (D C C (D O J a) rn-r _ CD (D v �' (D w 3 i' K o 7 (D M Q �' 0'cl rt O� O^ ri ;a o O (D Z p 7 O v N 7 Masonry 6G N v In n in c v 7 o n Sl1 A D O �. O O_ (D ^ Q. 3 W D M SU 3 �, N 3 --n O1 v N n Oq 0 j o_ '* DJ 3 91 3 z^ X N �. O Q �, -s ° (p m y O O —-? N 3 CD a m (D O 7 r^-r C V N ^ (D d — 7 fl- N _ �' =. O_ O_ -' - `G p_ N 7' N C 'a O_ -' `G - `G N C O_ `G :E O 3 v 7 7 _ 7 v O_ ° C. N 7 -O N -O N In N -s 3 v o V 0 -O M n n QQ p ^ O7 O- N O O7n (DD °_ N o fD N M N a O 00 pq r. 7 O_ 7 -O 7 Qq O N 3 7 < v ((DD = O- 3 O 7 vOi O Qo = C N `G U = N vOi ° t7ii (D X O a 7 m ° v (nD < N 7 N (D O V7i C o O_ olC - (D S 7 ^ 6 N N rD ° n -O N _ v Q p (D O_ o_ N 3 -O `° o_ L -O . D_ ID. oq p g W oa a N a 0 a 7CL — 00 .Z7 O -O (D Z p r- o C 7 -O (D 0 -^ , v n n O r* N n Cl � (D w N N N O- c M Del — O p M-a p 0 c (D N n N 0 N 3 O 7 o M N < -- Q c° 3 O - 3 s O 3 N _ �. 7 7 _ O O 3 3 _. O 7 'Y N N = rD (D = (7j O C 0'Q 3 !D 7 O N O 7 ° 7 OQ S O (D O in D !D (D N ° M p N - 0 C ,ni J In V U'i p - OQ ^ n N O_ — 7 C 2. N N N 00 j flJ O O ;o Q Lo _0 mw' Ln v 3 _ n!D p ca. v ul �A 3, —_ ;Q o_ O' C - O0 N -O V) CuC U -m O N Ui O -++ N T O rN-r O_ N n. m o- O ((DD O_ m_ QU,ON N vnrti _ (D 7 O_ O- O -O (D N Q - O Q _ � -O m N � N 0, 3 1 N r-r O_ Q ^. M (D (D Q O .-r � = ^ ti; N ID — 7 - � O 7 (D v 0- W OLO O_ N 0( 3 3 Q O O- C N (D o D N O (D CDN (D 0- o -. n D^ -ti (D= iG' O 7 fD N a� aN o Q 3 h O 7 O T7 i I U1 3 O (D co G N (D TI r 0 O Cl (D 21 a 7� 01 0 0 (D N (D (D :3 (D 3Di (D ID C: r) E CL < ID o CL Oq (D o UQ (D O 0 w Ili O -ili -00 0 C) 0 C) z 0 3 co O CD CD -n r- C) 0 0- CD O =3 C) CD (A Masonry W v In flr n v .p o O O_ m Q 3 W -^ v �, v �• v N 0'Q N �, v v fD x o O_ o o_ o- N p v n O (D Q3 3 N 3 O_ Z ^ (D 3 7 O v 0 O D_ N n `0 0 = O- cD — -' 0- `< `< O- ID v -0 Q �< `< Q 0 .P = O_ -' fD `n N OQ n 3 O C 7 0 °° !° O Q `G O IO pq Q ED `� O 0C N = FA'-0(A7 (D j O 7 in p• -0D O_ p tD o n in _ crq (D N cn N S to �p O -O Zr fD N Q fD O n 0 -O W a,O_ 0 N 3 W O_ fV S -O O_ -O -' ID CD o D, m � n = 0 m rD fD m 3 D - v � o S2 O v fD rf D -0 3 m -� 7 5 c O O N VVi !D W N OQ O_ CO O_ to to M :3!D ip v, v� C s O v :3 o - -. 7 o_ (D o m -.c A o n» i P T o N (D (DO v o — n O 0 -0(D D -"D O 0 0- -0 c N � N Vi . Q N C, O D p fD N O O C '-^'. N N fD zt o fp O n •-' J CD N O 0 3 O DN N -0 n, ro O_ n N M N v o_ 0 o a v rD 3 D_7. n. cD v n, 0 D ^ in a v m n. m v Q ----- - - - — - - - - - - -- - -- - ------ - . - -- ---- -- --- -- --- - - - D -0 v ^ r Q O v O_ to � O v m r O 0 m 0 O n m 0 m 0 N N Cn I l0 = i jO I -O o fD fD 3 o m C N N a O N3 O o S (D ID O O a �; C Ln QJ D 0 C n C 0) a o N r-' — _ J O- N a v N CT 00 Vf LL O a �. QO N p� O a v __ 0- � 7 Oq n0 O o C N _ Q3G N W a O N O p �. � 2 O cn o -6 N n c (D in O O. o N aQ ro i I I I I I i I i I I I Z7 O I I 0 z ..O O n a) 07 m Masonry c v v rD 3 m (D 3 m -0 of c - c l. a > > c I a, 7 o < ID < o_ (D 6 00' n O c s `< 3 L 3 a, (m m 3 w 3 0- O o c a, C o a) Q c' N c a, .n-' c a, n o n O 3' a, w LT C � m 7 P12. o_ m 0 o — o_ -1 aQ zr a, to w m .X-' m v (i m- -O m o W ` O_ a Ul n -o m o--a m D p p OQ Oo Q 3 (D (, 7 -- m < U m C to M N n N 7 O N N 7 N C O N d D v `< .n-r O (�D m q in O O - -+, 3 rt p N n N (D N m n in C n n v O a — o°'Q 0 --0 O vm :D a c (np w rD to O to (U �n rtr _ in m of N O_ m w C o m O 6 C _. 6 o- v o-tmi� Q 0. N �, O O O m O < fD in Q. `< m in m C to Oo N O- O Oo OQ m TJ Oo Q m -- A o n w Ln v m 3 n (U (p v O_ N i I N CDp - O m C O - OQ cc n -ow Q m O D 3 - D7 n � Q N 3 c 7 O 0o in m cn N 6 W n n w al W Q m O- O N -z -O O O n 07 _. Oq p O m n O_ N a1 C N T ;0 O_ N -O n to N N07 S N n v _O m A Q (gyp O -t m Cl- m Q o-Q N to O O 7 ca o' O `< N C m (D m to O N O C 7 O C m Q 7 0o C O C Q p -O _ .n-' v m n. In a O `� — rt ~' m CD Q O 0o o O Q 7 l< Opo ELT �. - n C (A . r CD w O cu N om `< O O Q. (U �n m .�-r m ❑. O v 0 N (D o_ N in O 0 �' `� Cl Ort to D O_ cn 3 O (D C fl1 m TI r 0 a CD 0 O o. 10 m 11 m N v Q O c Q N N = O g DQ N O_ p O� Ln C t 1 n to p O 0 O M D = 0) N O -p N N a N �` <_ — N -O W D -0 N O � N N Q' N n O Q � iT C_ N O_ (� n 3 p C n �_ tnl O p p m v -O W - O p p -p N C m p .p - p Q_ N 3 N 7 p n n f�D fD N' C (D p O V1 - (D O N fD O_ p OQ m N C N n' C N D O. _ Q VCi m N < — O olq!D N n pC N - G N Q. O N ' Opq 3 n fD O_ p Oq O !D N C N N 7 Q M N O n tp p `Cu � -O p O n N. �' N p n 3 N O p in v p 6Q (D to p n N N in tD Op p N v O_ j Q Q_ S Q N O N N _ Q p N N N Zr O N p >-0 a w 3 ni m Q a O p -O C (D O_ C Q N N O N O -O p C -p < Q. w 3 p m 0'Q z N p 7 Q O p 00 � I I i I I � ° O vi o v N 0 (D O n C _0 7 O 3 fD Ln n C !�D N � v 7 O- C Q. Z FD n O °- c Oq - -^ 0 m w fD O� O O O N N O (D Q ^ ^ N O O N c 0 n N s v = O z13 (D cr �. -O (D °- �. n — rn LAv 3 w I i I I i i � � I N S fD Masonry y v w o Q w N D a N a w v w -O Q w — rD -. O -0 Q n n N S = O C n G 3• O O !D O O S N Q 0'Q O< Op O.. < n (D ono Q w < a a o rD n N w � w fl D w X !� O Q 7 (D (D P O Q O 0- C. E ov D .+ (l N < -a p < Q Q N Qq -o N a'o w � O (D w v w n O Q (D n fD -6 a rD a s O rD n rD z O 7 O (D C N to w n O QCL Q 00 j N 3 S. N (D w ao mN O Q N (D CD — Q (D Qj D 91 0 �. °'cu zr (D • Q w= D O O_ p w n O = w w x v D p G) 6 n -O (D -O -O �ILO S Q -O �_ (D (D O N w -O -O n n N `G n 7 7 O — C O n - C n (D w S w (p N v O O n 6 Q d (D 7 j �' N -6 m (D < to v QQ D O n 3 n In w C -O rp R I� A a M (D n �, N 7 O w Q o rno T.' O n w j O)qv n w �, w _0 -O _ v a' N C (D Q w � -O O< fl' Ian o A N W (D v pq D p zr O n In n T 9- c � O w O Q FD n w O C -O A O w n �^ !D CD 3 to N �' (D p' v7 Q 9 D. 7 N w v�i w Q O n �, + — Q In M to �; -�ID O C. v Q O_ w N O 7 D 2 v Ul C) O �D '° Cn O O- C Q OU to -n o-p O (D N D m v NO O m m p -a -n Q(Do N 3 M. -rmmv C V n In a Q 0^ 7 I I (D rr C _Q C A O O O � Q w C. s 7 _Q. C n S 0 n = O O w Q O O vi 3 S w ;T C C 3 3N w (D :3n- o' < S n ID N ^ D W w 3 (A w N n M 7 p' Q O W ° w (D C Q O ,..' S rD ° T O O p 3 rD C 0-�O O n n (D rD w T w n In (D O O' V) Z -n -n w -n fl- S Q n OQ to Q N �7 w = Q N -O w < (D C to Q �' ° S (A Q N �j w N S O cn w ID w w 3' pwq (D L, " 2 — .� O O 0-3 S M 0' N 6 � n n n S N Q C Q C w 0 <. Q (D Q w fl- w n v Q C O (D n N• �. r'l Q O O (D M Z �. -n O Q "p C N N QCQ z 2 w 3 -0 C: 0- CD - C Q S S D w O -0 CSn 6 (D C C y 7 (D (D _ O 7 Ol O !D w O O C n S In . OjO C 5D _GQ N Q Q 7 7 0wq (D n) r S 3 O O OwQ (D n (D S � rD =3 O :3 O OQ w _ OR ID O 3 * a j :2w rj N w N to N Q °N _ O o 3 (D c rD 3 M v Q j ((D (D v _O X O Z (D n O n. (D c j D w M Q 3 O � � � I v 0 6 D O -O ; N- O N (OD Q rD ° = N O O O 3 O N N p n d Q —. S 7 `< ? C n C tD Q Oa _ Op In o < �^ N 'o O ID `G n d Q o O O Q O O� n N N oo 7 `" O OHO C Q �` O to n Sl! < r. n N < — n Q < Q Q — Oro Q' O N Q N 7 — OOo N O Q v O- O N `< W (D v 7 < < -6 -� rt `.< N Q o 7O -O C S n' N O Q 00 n N tD N OW O N fD vi Q m N p M 91 < � rD O C _ -" O °i rQD Q S rD vi N o- O O 3 3 O- v O 7 N 0 O OIQ 6 O N Q 3 N v 7 7 O Oo 7 Q n O 3 rD Q N O 7 G �. N 7 Q 3 rD ram" C O cn 00 O to O o O ,n.' N N D D Q C (Di (DO I Q D N in D _O v n rD O N D " O w 7 Q 4i — O �O N — O 7 in cu X to rD n" W N — rD cn 4/ N (D n rD to < crDii r* j < vrDi �-r d O to C r�-r fD in in C N O O 3 C ? O 7 v n O' N T Ov I ^ 7 N 3 n -O N N N cn o rD n `G Q rD in. �- rn-r C N fD. VI O C 7 N rD N r-r O l7/1 O fD O N X fD ii N VI a-O O Oi 7 (D c O_ n 3 _. Q v (D co 6 rD C r' n n)vrDi rD O l�/1 O v n N rD w5 C N �. (D lil Op n A W A 5 N 3 Cn 3 O rD N C 01 CD T r n 0 a m o_ O n m 0 0 m N i I� rN T_ O n -n n -n 0 m N T_ C n CD _O O O N n n n O _0 n n O O r* Q n rD n n m m v w d O rD - `G N " 3 ( , 7' 9 'D v fD 3 rt �. rD in N O to O aj rD O_ in N vni p 3olq K 7 N 7 7 �' n n tnn O_ O N 7 Q � I� it I K w 3 S O CD m D I ( N N (A v oq rn p p< m o to v v -V i- r = Ll Gl rn T w I ° O v rD 3 Q c E 0- ° n w ° o v c o aq fD w c o � o = n a Q v rD v n y (D o rt o fD o ° w m < �o o (D n, o 3 o �. a0 3 n n 3 j O °° O 'O (n �. 3 7 O 0 O 7 in ° a °' aq n -° - N OIQrD r-. (D I O 3 O N C O n -° (D (A � Q. fD � (D N I I I I i I i i I I I N O N cn o O (D O C N (D r n 0 m 0 O a v 0 0 m u, v K i�: �Z �: - m - - ^ O O 3 n n m m v D D D ° c o m v nN; c 3' °i. 3 0- O- a c a. 2DO n _mOv: Qn o °M — c o O S0S _ - m rt m O n Q _,m' m -zr 3 o`j N m 3 O 6 0. p(7O M0 m � , � N (D N 3 :3 OO_ G mOm N 0 0 ID CD O- nGv LA On _ o j m m 11 m n O n o v N O c s CTto n 'm0 N vmi 7 m 7 vmi n n vmi O m m m vci vi `G N n N Q m N m N T L O m d m m A _ O ,.., (A v W A N 3 U) 3 O (D N LU CD CD TI r n 0 o. CD o_ O n m 0 CD N Z5 ID 0 (D a, _0 -0 0 D , �� a s 3 :3 rD CD CD 0 3 c al (��, (D V) r) -0 Ln ID C Ln ID r) aj (D zr - 0 g� C: CU o- n m (D (D C- 07 M 0 M 0 Z, CT 0 0 Z 0 0 0 M, 0 X (D :3 FF �a ID cr 0 ZY M� o D (D C: 0- ID ET 0 w -0 0 77 rD 0 X, -0 0- (D =3 (D (D P5-ODWM =r D rD R- :T 00 w "J (D r) a- 0 —. D ID -0 -- 3 :3 rD o- o 3 n. ;:r r3 U, iD _0 M� rD Z) CL CWW w 0 3 M D N zi rD (D o Qq v 0 N Q1 In `" S N rD Q In N 7 OQ O a N �^ P O �D 3 N < rD U C Q S oQ N vi N N N v � O n N O S 0)rD rD M S N O O O S rD g a O N n S S ro W -n O r(D-r O_ !n 0 < 3 �' Q � v' 0'Q N :3 O- O — 3 N ^ O O O U1 s to S N rD N 7 o 00 -n O O ,. -O O o < N S n N S C a �, OID E3 N (D v S V1 N rD v j O- fl- �' o CD rD 3 O M n to in rD :3 o N N .O-r 0)O_ = o � d fD v m 7 S n S OQ N U, .N-' O �, O V7 S 9 _�_ N C N-mm (D S M A D C n S N -O 7 O_ CS 0- fD N j O -0LA (D 3 .-r D rCL S v — rD W Z o O -O ni 0 6 O o x- O G D) LT N - O.___.._..__._-__... _...-......__-. ____.._._ ... .. _._ O N s cn m ' � N --< SL D1 In In (D 00 N �+ ,+ -n N O W O N N O 3 fD J N O (D Lj N N -p 7 ri T in rt O 3 N O O (D Q -p O 'D 7 7' O 7" (D S vi 7 N -* 7 `G N -O fl_ to -O N — t1J Q N n N -• O 7 n n N v C N -O K Q Q_ in O (D ID7 to 7 N (n j D! N a' Vl Q_ O r+ O ^ tD O O QQ 0-n 3 7 O (D O_ rDD (D (ET O ID (D 7 a 0 p n (D 7 C N C ,(Di < N tD C C p O _ to v O O n U'i O S O (D (D p < (D N D _ D 7 0'0 SL Q (D N (D �- O — 0'Q (D - • n N n D1 7 N r7-r — N d Ln O � N — N — N Z CD O� O N ram* (3D a- 0- + 7 v7rti O O 0 O ' m 7 3 co T O N CD -n r C) -- ---- --- - o n m o_ O n m 7 CD m - - - - - - - ------------ - ---- N N_ W 0 N N A N _ _0 n trq O C O v N N Q fl; D , Q- o ',, G � N N W A W N I -0 n O w 6 (D i Masonry i D O O n G !D O_ Q N 7 7 tro 6 p (D Di n v N O_ O 7 to zT - !D S (D 03Q Q _" — O In v — S N In 2D -0 N p D a N ^ O 7 n < 3' O G Q S o N : 0OQ N � O G N D) Q �. tro O N n O p- N 7 (D n _ p W a N N (D N ^ N �. (D O Q � (D (D " N O- E. Q 3" 0'o D q n !D G O p3 G Q N p- N 3 pq S O v � trio N -0 ' O N W (D 9i N tnl O O_ � D n (D 7 0 (D rr 06 0 n j cD DJ O_ O N T. O n z O j N 00 O 7 p N _ 7 O O 0'Q .Q Q fD p 7 fl' p O_ O- N S (D S n O vi N (D — N p 3 p Dr p O_ S (D 7 (D S — = (D N — n rt N p- N N o -O S rD 3 °q w p v N D N G -. Q n N O G -o o G (D c n S vCi w'n 3-0 -O (D fD a fD < O n (D Q o N d n S -0 7 c C 7 3 3 3 7 O p_ O j < 0 O n C 0 S (OD Z (D `G S o C O v-0-0 S N 0O O (D 5' S n 3� (D 7 o N = 3 Q - N 0 3 ^ I D = N O C r O O ^ to C (D v O N o 7 D N in Q �, 00 O (D rD m Oo D' CO*-n Q � rt 3 n (D p 3 (D tra D (D 3 n .=r N N v� v 7 N O D 7 p_ j (D ) o -O p m C -' Q ]' " " tD 7 ^ rD :� v Q v N n rD v p N � ro X n rD -6 N rr �' O_ - CD vi In V1 0- vi (D (D W O -O O n Ln N N n 0- 0 N I !rD (D 0- O Q T1 O O ;;a Q 0 u O 0- n S N O n_ 2, 0- V) N (D ;a Q - -O (D 3 - m -n O O' C a n -p N -O to n `G -- --- -O (^ ----- O -- -n LA 7 Ln - O CL 'O �. -n S cm,to S N O SOIQ O O O O rr " 7 < 7 O_ v _ 0-3 O N (D �' d p_ N 7 S -p N O_ 7 S trq S N 4 v v D- ry O O v rD n ID D - O G ID O_ CD -p v v -O -0 OG O 7 n-`G !D O_ 7 v v S O O- C Q O p O_ n 6 C Q n S 0 n (DvOi Ln v Z7 Q vi (D 3 O S N p (D O (D w 9 -n 3 9(OD (D r+ (D LAN `G D1 tro N O S N G Q �' rl N D O CD rD O_ 0� (So �^ tro p n cn N O_ Q - Oo D n (D G p G Q a o O =Y N p N 7 M - r-i S g n 00 � (D o. o 3 O 0 N of r 3 N `G p- N D n (D -O v Q C - N 3 Z O j N 7 O_ rD I S -O < N _O p (D 0)O d p 7 W C Q O N N(D O1 Q � to N _C Q oO v rD V_1 bQ � O D Qp 'O — !D Q p r+ to (D —. n N `G to 0) — ((DD N :3fD 7 0'O N Q -6 7 �' QQ N 7 p- 01 7 Q N '6 N V1 — (D -6 v 7 (D <. !D -O O << N Q p 7 n W O Q O N N N S (D Vl W 7 N O lOn 7 v O 7 d d rD n O � n — O z Q CD Q O O �_ (D Q N � Utl O Q 3 'O 7 7 3 7 r+ 0' 7 <_ (D N Q S In :37(D 6 !D On- Q (D vi (D —. In 3 v"i rCi Q bQ (D 7 N C (D Q vl O C r_* O 7 In N Q a D — n N 7 5' v 7 M v -p — n v 7 n QQ o -n vl 7 p_ In Q `� (D N 7 7 7 p_ in C '6 `< 7' m 7- O z m vi d in S N J vID S (D 3 O 7 3 tD O v (D a v C O— 0 O' (� vl 3 Q O O vl �, O N to N rD to pi 7 p_ In S O n O 7 7 7 -- O 7 7 v 7 Q -O N .7+ 7 OQ 0- ,C-r O Q- 7 Oq 3'cr n C (Qp 06 7' n 3 `G (D 7" n (D -O N 7 (D 0 O m a' — 3 3 (D tD S n tD N -6 7 7 ,�-r. O p 7 3 to own 7 Q Gl to (D N (D to v Q 7 M ? S O .C-r < !D (D n N `�nr 7 D N Q i in N _3 0 (D G v m -n r O 0 Q m o_ O a m 7 0 m rn N N Cr c o N S N 7 � � N iD o °' N 3 �, 0- 0 s v, rn v, �n a 0 n v a o- ^ 0 0 c °- v g n g c v -0 o c 3 o c c o N m c m o 0 0 -0 m o v 0 in rp m ,Y o� -O ° v n rn v� o- � � to �_^ D < ] °- 'O n �' °- o' o m n. ° o _ O M a o W = w v °q 3 < c m °' v v o N o n 0 0. no ° c o N m ° o _ o m v s(DN 3 m Q w O n o (A c m c m n m m m n a ^ c CD- — m 3 m 7 _ m n N O N n °- N C N N S to N m S Q `G In m V1 0 O Ln C a N .) m S < _0 Q N 3 � C N !D `< m v Q O N d m — m O °.. N — 3ci S m m 0 m CD < Q n < N (D v = 0 m m — S w O m 0 °- In N W A if N 3 U) 0 m m m m r C) 0 0- CD o_ O n m 0 0 m m '-V InLno-p-w-;w MLInul 0 =-ou-qs;g<ow o -00, �ID _0 _0 M C: _0 �o go (D rD C: _0 < g m -V - - , rD Q1 M C: rD m rD a, u -0 0, 0 a) rD 3 - 0 r (7D' - 0 o 0 0 OQ a) 0 n c rD (D W 0 ai CD < " W rD < lu D (� 7 :!. rD 0-�,aL M= ' In 0) Ln 4, w F, 0 (D (D -0 o D CD 0 (A 0, 0 (D 70 Ln (D rD — 0- (D (D aj D 0- 2L 0- w vi (D (D < (D X C37 ---- ------ Masonry rD ;:w :3 rDto C: I'D C: I'D > rD D -0 C: Q) r m -0 fD a' 0 5 OQ �n :;- pl 2! m C37 Uj C37 ca. N) > L z m 0 N 0 :D 'D o 9 ci n 0 q 3 c� rD Q, X < n CD rD 3 w Otl 0 C- (D ID 0 to I m (D -o m 0 on Oq 0 Cy. r'D _ 2- (D Q, - 0 o a) :3 2. _0 0 10 5, w 3 g to zr N 0 0 ul (D CD zr (D m m rD cu 2) w c rD w 0 D �A 0 73 Oq !A 5* On C: :7 rD cL OZ3 Q) 73 < L CT < CD < M 0- rD < cL (D ::r o Qj— 3- c) m -o -1 3 O-ou,3-6, 0 m c w Dloaj - w L4 w m w 0 m 0 0- Sl u :3 -o o- tj 0 o- q -o 3 (D w o w :3 LA E; 3 E; ID m n- - 0 = C) c W A rD -gDOlg2 3 c (D (D ul n 9 �:v -rD (D rD rD io n 0 n n rD rD n FD 0 ca. o 2. I (D o :3 o c, 2- :3 0 5' 70 5*0 m 7" A to 0 o ul ul) _0 w rD 3 (D rD o (A Ln _0 a) (D n3 rD FD' io _0 I 0 0- rD 0 rD m 0 3 w m O 0 (D CL 5* > ED -0 -9 0 I - - E: 0 C, < '0- -0 3 < �; rD 3 3> rD Ln (D CIQ La- (D O (D Ln Ln _0(D 01 73 C)_ (D FD' Q' o- n tA fD (D a 00 N (D N N �, :3 CL LA0 7 a s M O S O a -O N O l0 Q N C N a N Q a a N S n N N Q O c fl_ CD -6 n N O 7 (DD 3 Q Q On S vOi > (A '"' OQ ^' t�i ID Q Q 3 N to S n O O n" �; C O_ 7 .-' W C — (D n' vi `G '-^ C n C v,' C C C O v rr O S 7 (D N n d M N (D n �' C O 3 N 3 O* 3 O n n N 7 O N r+ r-' SU f3-r QQ S 7 Q O `� a p- O 3 O O O v' O O 000 7 _ in in ,^y vCi O O S 6 C O v QO N in -^ O O in N to S 7 O O O O SQj N � v !D O N d fl- fl_ O Z —� N N OG N OJ n Vi !D S O S S Q 0'Q O (D N v N' `G O. `G fSr a OD •� 0 N N N 3 S 0 m N N (D T r C) 0 n m o_ O a m 0 m cn v 0 a N Z N O 6 (l N C D �. O O n a j 3 v j -6 S OS 01 6 O (D -00 3 O_ rr 7 7 p 7 (D p_ - 7 — < C O_ l l C (D v v N �< (SD S n N N LA aq (D S1J SnL (D O X N �' N n 90�i N O_ C (D N (ND N Q O S _ •- N n N N N (D S _ N O O G� 7 n o 0 5 < a ^ m ^ aq n Q v �. � p v ro D o oq o m vFDi Q (l rD 7 v O0 N O FA nn O (D O `< bq C C (D O to (D 7 S O_ (D N c�ii N (�D N O 3' O O N :J N O- O0 N (D m - Qq z n O N se W K N 3 S O (D N G N (Q (D T r 0 0 0- CD o_ O n v 0 CD m u, (D 3 0 Masonry OMOM :T0ET 7 D _0 3 OQ - ID 2 W rr.0 0 D m Qj M -0 73 CL 0 D. -_0 .Tam OQ -0 < 0 ET vl (D N (D (D a D 5' OQ 0-1 :3 0- _0 _0 Lo 0 -00 M :Y 0 rD , 2. :3 - a n a C: i; aq < (D 0 M Q- o 0 —n CT r'j - ED C: ZT 0 -0 :3 ul rD M 73 (D. ID z, :3 r) to O (D GQ 0 (D V, 0 :3 9 3 -0 (D 9 Ca. CDL -0 w CL — W 0 0 ;'U OQ 3 Z) c ON 5 . :3 CLQ. F) tail (DS 7 -0 fD LU TD 3 mO- E Z) (D 0 (cu 0 o -01 o < M C)- < rD cr 3 3 5-,D-. n (D 0 - q -0 7 (D M 0- cn 3 Z) LA. E) Z) > < ID D. cl 0 (T E— 3 n 0 < 0 M U) w 3 cr (D < 0- M u C 0 WD , Om rD X r'D 0 :3 0 Masonry (D (D va (D ID 0 13 0 0- o_ rD o (D 0- CD rD 5T LA 0 CT (D rD 0- -a (D 0 (A. aj w CD o 0- o o CL (D 0- rD 0 < m Iv CL Ln rD C: Oj o 0- m L-A 3 :3 0- X m rD !D LI). (D CD rD 01 — m D 73 m o 3 ED 0- c: = 0- 7Q o , z x o n (D E o Cn 2 (D (D 5' Ll (D E: m 0 (D D- NO E: n T � z � O -O .r 6 — .-- -- ----- Masonry M fD v 7 ? v 0 p 7 Ul C C lIt A rs W , 6 N ; —gip --n Q _--__---- N N7 fD � c - v O N 0, o !� ° Q D z S. Q v S D z n as - o 3 m =' a� ° O 7 3 ID 7 - I Q N X n •< n 7 N O in OrD ((DD O N O O N 7 Q N S 3 O_ 7 Q O- rD C D- .� O_ 4i 7 7 A N O- C O v (D (D a �G Q vNi rD -x0 w NO N O� O' D_ -� O 7 M �- p7q Q Q,G S v -O a j QQ ? 3 N '^Qi v 7 N °w° `< rD!AO v7i Q v `G a < N 4 rD rD E O 7 < CD rD fD N to O- O O n rs Q OQ N < 70 v�0i (D (D O a rD Q `< OO ^ 7 S n O N `S 'a � P N N O W C Oq N rr) 7 7 N O n' 0 < (D -0 N 7 C v7i N O O 3 v On C - n Ln Q. N O S fl N < < v lO CL m m N o v C a O 7 D D < n Zr (D Gi 6 SF. rD 4ni 3 c j ED C v a Ort O O7 jrD crqG 6 7 a 3 v N - G rD O -O. -O LF n S n S 7ID n vrD 7 Q O:3 O v O ` O = `�' v O r) 7 n rD N 7 a N O rD Q O to N 7 S to N Ort - `G 0- O O O O N 7 C Q N SU 7 N v � .� `G 0- `G to fl- 7 Q (D -0O 7 O S Dl 7 Q n N S C � - N n OJ (D 3 o (D rD (D O X C p O CD 3 -o o - rt u X fl (D 7 n Q rP -------------- - (Da un ai (D v ul D. n ' I - ---- ------- -__.-__- .__._- _. I I Q L 3 � I m I tq 3 U) 3 CD N D (D v cr O 6F N Fl,' :. r-' v CD v O• O z In rD HT O :3 to N rD v rD In O Q N rD S O S v 3 rD O 0 rD N N S rD a Q D� Q3v in O rD � v N n. - O_ v O O rOi O _ X D !SD 9' D O 0-Q. Z)NNO- O < O- !rD v N O C !D fl v p oM rD N rD p O S S n rDO Dv cu O- D O OO < rD v rD O rD < D S -- -rOOND p -n rD SSOn q vCA -_� , O o w w w 0 N U� N A no 3 S O CD O C N (D r n O n m p_ O n v 0 m I i rcu o fl I � 6 (D Masonry 1 O pi W N Q v " N — ; n O 6 -0 C N D -O N O OG -O N W N N n (D n — (D W z -- O n < C 0 0'Q O j. OC N Oq O 0- Q Q. 7 Q:3 pq n N N Qq � -O O Q rD s _. = S (D E -O � OrQ Q S Q O j ((DD rD N r) Q N O Q 6 7 Q S j (D �. S Q 2 OQ fl_ Q N —. -O Q —. (D S j (D :3 (DID 3 i ^. O 2 3 'p (D ^ O_ O 0- 2 Q W 91 3 S N � tU S C � OS N a O OQ rD O O N N 03q 7 O N 7 r (D V Q (D 0 -O -0 O O C � n cu — 7 —1 II I 1 C o � I I 1 i I I I I J i