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Raymond Place_Schreiber CommunicationPage 1 of 1 Jeanne Schneider -Raymond condo From: "Tom Schreiber" <t.schreiber@mchsi.com> To: <rdbuol@cityofdubuque.org>, <dresnick@cityofdubuque.org>, <rjones@cityofdubuque.org>, <klynch@cityofdubuque.org>, <jconnors@cityofdubuque.org>, <dvoetberg@cityofdubuque.org>, <jschneid@cityofdubuque.org>, <ctymgr@cityofdubuque.org> Date: 06/11/2008 12:09 AM Subject: Raymond condo Dear members of the City Council: My sister and I were researching the vested rights issue tonight and found that there is a very good chance according to case rulings by the Iowa Supreme Court that the Kahle development did not have "vested rights" last week when the moratorium was imposed. We found legal rulings by the Iowa Supreme court as follows, using the Iowa Supreme Court's Language: Vested rights were denied a landowner ultimately by the Iowa Supreme Court who only had an architect's drawings and no working blueprints, as furthermore they had no materials placed on the construction site yet, no earth work (I believe they are referring to excavation for foundations) started and no construction bids sought or let. For example, vested rights were granted when the developer in another case had already excavated basements and had contracts for the foundations to be poured. Could you please revisit the councils voted acknowledgement of Ms Kahle's vested right, as according to Iowa law it appears as though she does not have it at this point, as she has not submitted any expenses, and likely still has small costs in comparison to the ultimate cost of the project. Could you ask her to submit proof of expenses immediately, before she spends more? Thank you for your consideration in this matter! Tom Schreiber Mary Schreiber Mark Schreiber Patricia Schreiber file://C:\Documents and Settings\jschneid\Local Settings\Temp\XPgrpwise\484F17C1DB... 06/11/2008