Canvas Prod. Ltr - Busted LiftLAW OFFICES OF
REYNOLDS & KENLINE, L.L.P.
DAVID L. CLEMENS
WILLIAM J. MAIERS
CHADWYN D. COX*
MARK J. SULLIVAN
JEFFREY L. WALTERS
JENNa~ER A_ CLEMENS~CONLON
JOHN T. NEMMERS
TODD N. KLAPATAUSKAS**
KlM C. RODDICK***
Of Counsel
LEO A~ McCARTHY
PAL~ M. STENJ~OND
SUITE 222 FISCHER BUILDING
P.O. BOX 239
DUBUQUE, IOWA 52004-0239
TELEPHONE: (563) 556-8000
FAX: (563) 556-8009
E-Mail:rkenline~mwci.net
April 12, 2002
Mr. Terry Duggan
Mayor, City of Dubuque
City Hall
50 W. 13th Street
Dubuque, IA 52001
Mr. Michael C. Van Milligen
City Manager
City Hail
50 W. 13~ Street
Dubuque, IA 52001
Captain Paula Gieseman
Dubuque Law Enforcement Center
770 Iowa Street
P.O. Box 875
Dubuque, IA 52004-0875
Mr. Michael Koch
Public Works Director
City Hall
50 W. 13~ Street
Dubuque, IA 52001
Ms. Jeanne F. Schneider, City Clerk
city Hall
50 W. 13t~ Street
Dubuque, IA 52001
Dear Mr. Duggan, Mr. Van Milligen, Ms. Schneider, Captain Gieseman, and Mr. Koch:
I represent Canvas Products Company located at 182 Main Street, Dubuque, Iowa, and its
owners. They have asked me to contact you on their behaif and formally voice their objection to
a request made by John Finn, owner of The Busted Lift, for a penrdt and authority to construct
and maintain an outdoor patio at 180 Main Street. Certainly, you can understand my cli~mts'
concerns regarding the nuisances associated with an outdoor bar, including increased and
elevated noise, litter, and destruction of property. Further, some of the business hours of
The Busted Lift overlap the business hours of my client, Canvas Products Company. We
anticipate that the operation of an outdoor bar will also result in disturbances to my client's
business during operating hours. In evaluating whether or not the ord'mance applied for by The
Busted Lift is approved, it is my hope that the City of Duhnque remembers to consider the
LAW OFFICES OF
REYNOLDS & KENLINE, L. L. P.
Mr. Terry Duggan
Mr. Michael C. Van Milligen
Ms. Jeanne F. Schneider
Captain Paula Gieseman
Mr. Michael Koch
April 12, 2002
Page 2
history of noncompliance of city ordinances by The Busted Lift and the history of lack of
consideration given to its business neighbors. It is my understanding that the St. Patrick's Day
outdoor party hosted by The Busted Lift was held without the necessary permits being obtained
in advance for the outdoor tent. Further, the tent was up for an extended length of time without
permission.
We hope that you take into consideration the concerns raised by my clients and other
neighbors of The Busted Lift before ruling on this ordinance and seek further input from the
neighbors to determine the extent of the impact the outdoor bar will have on the surrounding
businesses and properties. It is my understanding that some of the properties in the area are
residential, and the sounds created by an outdoor bar will certainly be a problcqu to anyone trying
to live or raise a family in the general vicinity.
Thank you for your consideration of my clients' concerns/.
/
~/' Sincerely,
/
/Jennifer A. Clemens-Conlon
JAC:pmm
cc: Canvas Products Company
S :\WP8XPatkLetters\Clemens-Conlon\CanvasProducts041102.wpd