IN HE CI-IANCERY COURT FOR JEFFERSON COUNTY, TENNESSEE DORIS LIGON d/b/a HIGHLAND OAK FARMS, Plaintiff/Petitioner VS. JEFFERSON COUNTY, TENNESSEE and the JEFFERSON COUNTY BOARD OF ZONING APPEALS consisting of members TERRY RENEAU, CONDON BATSON, SUE SPRINGFILED, WAYNE SCHRADER and ROB WILSON Defendants/Respondents No: HA is W.n.Nr.."v =3 Cl 3 -H 1" PETITION FOR WRIT OF CERTIORARI Comes the Plaintiff/Petitioner, Doris Ligon dfb/a Highland Oak Farms, by and through counsel pursuant to Tennessee Code Annotated section et seq. and seeks the Court to review the recent actions of Jefferson County, Tennessee and the Jefferson County Board of Zoning Appeals and for this Court to issue a common-law writ of certiorari to bring this matter before the Chancery Court of Jefferson County, Tennessee, and to declare the December 18, 2012 actions of the Jefferson County Board' of Zoning appeals to be null and Void for being illegal, arbitrary and capricious and in Violation of applicable law. 1. Plaintiff/Petitioner ("Plaintiff") is a citizen and resident of Jefferson County, Tennessee, residing at 2240 West Highway 25/70, New Market, TN 37820. 2. Defendant/Respondent, Jefferson County, Tennessee, ("Jefferson County") is a political subdivision of the State of Tennessee and may be served with process through the County Mayor, Alan Palmieri, 214 West Main, Dandridge, TN 37725. 3. Defendant/Respondent, Jefferson County Board of Zoning Appeals is an agency and instrumentality of Defendant Jefferson County, Tennessee, consisting of members Terry Reneau, Condon Batson, Sue Springfield, Wayne Schrader and Rob Wilson and may be served with process through its chairman, Terry Reneau, 628 Briarwood Drive, Dandridge, TN 37725. 4. Pursuant to Tennessee Code Annotated sections 27-8-101, er seq. the Chancery Court has jurisdiction to hear this Petition for Writ of Ceitiorari. 5. Venue is proper as Jefferson County Tennessee, and the Jefferson County BZA is situated in Jefferson County Tennessee, as is the property at issue, and the events, occurrences and transactions described herein occurred in Jefferson County, Tennessee. 6. Plaintiff, Doris Ligon d/b/a Highland Oaks Farm, has standing in this cause. Plaintiff operates a family owned farm on property adjacent to property proposed for use as a cadaver research study site. Plaintiffs drinking well is located very close to the proposed location of the proposed cadaver research facility. Plaintiff, as well as a number of her neighbors, will be adversely affected by the noxious odors, emanating from the cadavers as well as the contamination of the air, water, soil, insects visiting the corpses. 7. Arthur Bohanan, a citizen and resident of Jefferson County, Tennessee, owns approximately 70 acres in the New Market Tennessee currently zoned A-1 (Agricultural-Forestry District) under Jefferson Counties Zoning Ordinance ("the Property"). A true copy of Jefferson County's Zoning Ordinance is attached hereto as Exhibit 1. 8. Mr. Bohanan has expressed the intent to donate a portion of the Property to Carson-Newman University for the study of the decomposition of human and/or animal remains and the extent to which the natural composition processes affect the surrounding environment, and consequently the public health. 0 9. When Mr. Bohanan sought guidance of Mr. Tim Seals, the Jefferson County Compliance officer, as to Whether or not the use of the Property would be appropriate under the Property's existing zone, Mr. Seals informed Mr. Bohanan that the Jefferson County Zoning Resolution did not have any provision addressing this use and he would need to seek the guidance of the Jefferson County BZA. 10. This matter first came before the BZA on November 27, 2012. At that time Mr Seals addressed the BZA and advised them that he did not know what the appropriate zone for a proposed cadaver research facility would be and that he did not think that the proposed use was a cemetery and advised the BZA of the same. 11. After hearing input from Mr. Bohanan, the undersigned and several concerned neighbors regarding the proposed use, the appropriate zone and concerns that an approved use would be unregulated under the existing zoning code, the BZA decided to table the discussion to obtain more information regarding the zoning of other cadaver research facilities outside of Jefferson County. The motion to table the discussion until December 18, 2012 carried unanimously. 12. On December 18, 2012, the matter came back before the BZA for consideration. Before the BZA was information from the County Planner, David Williams, who informed the BZA members that per Section 9.3B of the Zoning Resolution if the use is not similar to any use specifically noted in the zone, then itiis not allowed and the BZA cannot approve the use. 13. Specifically, Section 9.3B states as follows: Uses Prohibited. Any item not specifically noted above, unless the Board of Zoning Appeals deems a proposed use similar to a type listed above [in Section 1 14. It was the County Planner's opinion that the proposed use of the Property as a cadaver research location was not similar to a cemetery or any other use specifically allowed in the A-1 zone. The County Planner further warned the BZA that approving a use that was not specifically approved or similar to an approved use would be to exceed their authority and to act legislatively instead as a quasi-judicial board. Finally, the County Planner warned that an approval would mean unregulated use of any the Property for cadaver research as the existing zoning resolution does not contain any regulations. 15. After limited discussion regarding the authority of the BZA, the proper procedure for amending the zoning resolution and placing restrictions on the use of property for use as a cadaver research facility, a motion was madeto accept the use in an A-1 zone. The motion was properly seconded. 16. No member of the BZA identified what enumerated allowed use the proposed cadaver research would be similar to under Section 9.313 of the zoning resolution. 17. Following the motion to accept the use in the A-1 zone, a roll call vote was taken with 2 members voting against, 2 members voting in favor and one member, Ms. Sue Springfield abstaining. Following initial discussion as to why she abstained and whether or not she could abstain, both the City Planner and the BZA Chairman, Terry Reneau announced that the motion failed. 18. Despite this announcement, the two members who voted in favor of the proposed use continued discussion on whether or not a member had the right to abstain or if she had the right to change her vote. Without there being a motion to reconsider, Ms. Springfield reluctantly changed her vote from abstention to reluctantly in favor, and the Chainman announced the motion to accept the use in the A-l zone passed by a 3--2 vote. 19. The BZA did not provide any rationale for its decision that the proposed use should be accepted in the A-1 zone. As such, the decision of the BZA is illegal, arbitrary and capricious and is therefore null and void. 20. The BZA failed to follow its own zoning resolution and its decision did not comply with Section 9.3B. As such, the decision of the BZA is illegal, arbitrary and capricious and is therefore null and void. 21. The record is devoid of any material evidence which would indicate that the proposed use of the Property is similar to any allowable use in the A-1 zone. As such, the decision of the BZA is illegal, arbitrary and capricious and is therefore null and void. 22. In declaring that the proposed cadaver research facility "has to go somewhere" without authority in the existing zoning resolution, the BZA's decision is illegal, arbitrary and capricious and is therefore null and void. 23. The actual result of the motion to accept the proposed use in the A-1 zone failed by a 2-2-1 vote. The BZA failed to follow proper parliamentary procedure by failing to make a properly seconded motion for the vote be reconsidered by the BZA. As such, Ms. Springf1eld's reluctant decision to remove her abstention, after the Chairman announced that the motion failed, is illegal and therefore null and void. Ms. Springf1eld's reluctant change of her vote came after another member wrongly told her that she could not abstain. 24. In the alternative, Ms. Springf1eld's actions in first abstaining and then reluctantly voting in the affirmative after facing pressure from the members that voted in favor of the proposed use in the A-1 zone was arbitrary and the first vote, with her abstention, should be reinstated. 25. By declaring that the proposed use of the Property ought to be allowed in the A-l zone, the BZA has exceeded its authority as a quasi-judicial body and is legislating by creating new use in the A-1 zone that was previously not allowed. As such the decision of the BZA is illegal, arbitrary and capricious null and void as it exceeded its legal authority in its actions on December 18, 2012. 26. Plaintiff is a small business as defined by Tenn. Code Ann. 29-37-101 e1'seq.; therefore, she is entitled to recover her attorney's fees pursuant to the Equal Access to Justice Act PREMISED CONSIDERED, PET ITIONER PRAYS: 1. That a common-law writ of certiorari issue to bring this matter before the Chancery Court of Jefferson County, Tennessee, and to require Defendants to cause to be made, certified and forwarded to said Court a complete transcript of the proceedings in the subject before it, contained also all the proof submitted to the BZA in this matter as well as all other documents, petitions, memorandums, or reports which were considered by the Planning Department and the BZA in this matter; 2. 1 That this matter be resolved on an expedited basis, pursuant to Tenn. Code Ann. 27-9-1 11; For this Court to declare that the BZA exceeded its authority in approving the LA.) proposed use; 4. For this Court to declare that the BZA failed to follow the provisions of the Jefferson County Zoning Resolution; 5. For this Court to declare that the BZA lacked material evidence to decide that the proposed use of the Property was allowable under the A-1 zone of the Jefferson County Zoning Resolution; 6. For this Court to declare that the vote of the BZA failed by a 2-2-1 vote and the subsequent reconsideration was arbitrary and did not follow proper parliamentary procedure and was therefore Void; 7. That this Court declare that Plaintiffs farm meets the definition of a small business under Tenn.' Code Ann. 29-37-101 et seq. 8. That this Court enter a Judgment on behalf of the Plaintiff finding that the actions of the BZA with respect to the proposed use of the Property for a cadaver research facility is illegal, arbitrary and capricious for the reasons set forth herein; 9. That this Court enter a judgment for Plaintiffs allowable attorney's fees pursuant Tenn. Code Ann. 29-37-101 et Seq. 10. That this Court grant such further relief for which the Plaintiff may be entitled. THIS IS THE FIRST APPLICATION FOR A WRIT OF CERTIORARI, JUDICIAL REVIEW, OR OTHER EXTRAORDINARY RELIEF IN THE CAUSE. NO OTHER COURT HAS REFUSED TO GRANT SUCH RELIEF. This the day of January, ur Seylnou1', If (BPR.NO. I Benjamin C. Mullins (BPR No. 20 FRANTZ, MCCONNELL SEYMOUR, LLP P.O. Box 39 Knoxville, TN 37901 (865) 546-9321 Attorney for Doris Ligon AFFIDAVIT OF DORIS LIGON VERIFYING COMPLAINT State of Tennessee County of Knox I, Doris Ligon, after first being duly sworn according to law, makes oath that I have read the foregoing Complaint, and that the facts set forth therein are true to the best of my knowledge, information and belief. This 7 day of January, 2013. DORIS LiboN HIGHLAND OAKS FA EL Sworn to and subscribed before me this 7 day of January, 2013. I Notary Public . OF My Commission Expires: 7 - (7 'r 2 0/5' 3 COST BOND Frantz, McConnell Seymour, LLP, as Surety, is held and firmly bound unto the Clerk, Knox County Circuit Court, for the payment of all the Clerl<'s costs awarded against the Principals in this action. To that end, We bind ourselves, our heirs, executors and administrators. The Principal is commencing legal proceeding in Jefferson County Chancery Court. If the Principal shall pay all the Clerl<'s costs which are adjudged against it, then this obligation is void. If the Principal fail to pay, then the Surety shall undertake to pay all costs adjudged against the Principal. Mandated by Tennessee Code Annotated sections 20-12-120, er seq. FRANTZ, MCCONNELL SEYMOUR, LLP .- -: ""Iv~II::(IIJIIHI II, ,(lIqI yt'gmI'~91nthW2I'll I I I I .I.I I I Ir I I Irlnificl; I ,9 II . I .-II.) I I Is IIMI 'cgInf AHIW <<"511 "7mImfiww -awn EIBLLEESBB 331550 awxmuz 23:3: HemFail 1.3.334' - I I ll |iIa"k"'la-II5..-II wI,Il '13"'nw:Iurt, Ilegfiw fit Fiji,' HI II . ll(d I I I I I '|5-"hiIerson 01111 I . Iwyw - -3 aIjtfi I. 'f I I I: JigIJILJ 33m.hMmw?mIIwwIw: II I . IfirIulr II Ell' I 5' I It': ll7'04? A I I I, AIHIH II-J 'finflw - fpfil repare Planning V180 erv Ices I615 N: I I t, A n.uIfiy.;y uI* I I 35' If1334'is'fiflfif ff' .-.iSe.011tain Am dm is - 3 . vzggag I31 Igx 0.11, 5 311 .511 J70 March '4I_j" Ia]? I I93. II I I I I'llvgfi %uwI - I I. I I I F5\llup("fin Ilvfil isII"' . ILV I Ah'fi; ladl'I| I I II ml 12/28 SNINEIZ 28:91 I '1 1 nfia.' 4' -. 123: I I A II -II. I ii 251*' sf?" _a - - - - {:lr't" 54:1'fig II .- *1 'lg'Evcry Building a:I1dUse .. went" I: I s. . . lips; u11d1ng "31; .. I . I filfi! flu I . I fill'-lln.53, ,3 1 ";;$utcmob11e . .- . -, runOccu ati fitPark I -. I I . ff Standards I Ii'! 1 -5 I - I 'mt Standards for ;l I I I -"Yards, Dumps, and Yardsya" standards for Sanitary Landfills ?-"Vigil m?1:MDd1fiQahDnWzpord 4 hi . . I I fI)\'fix I I . 1 r' ,Hfl|-W5' Inn33"ail. . I 1 I LIT, IntII, {dint}; I. a I I'INF 'ill 5. I3: I I I a "flu 1'1 .I (I I. I II Iii)", . . - f:xIra 'c23:91 I I 'ad: fiatTABLE or CONTENTS - 'Ill' I if I -winu bits"IiS13241Ii\Pit__fl RRemdenimal R--pod Commercial DisuictIncimztxial District, 1.2 District, RR I I . 3: ..-.. .. - 2:7; I I I I II-'nixI-I Iefi A I fig""Is': I . -ml' '5 "tits I 3.71} \l (I 'afar -fl\huAppeals :Jrr:,JgfittIgption an ax-Iaance eann YITI I I 12 I '-..-In>> II 'If l' 'it, ii 1 . in-''cl 331 5::91? ETEIE-SIZI-HUI - -- I "sf: I .: II fiwfiwafiIififi Ar I (I PURSUANT TO THE AUTHORITY GRANTED BY -.uvw~ OF THE TENNESSEE COIIE ANNOTATED To RESOLUTION OF JEFFERSON COUNTY, THE PURPOSE OF PROMOTING THE PUBLIC MORALS, CONVENIENCE, ORDER, PROSPERITY PROVIDE FQR THE ESTABLISHMENT I THE BOUNDARIES OF JEFFERSON COUNTY, I THE CORPORATE LIMITS OF ANY JEFFERSON PLANNING TO SUCH DISTRICTS, THE LOCATION, HEIGHT, OP STORIES, AND SIZE OP BUILDINGS AND PERCENTAGE OF LOT OCCUPANCY, THE THE DENSITY OF POPULATION, AND THE AND To PROVIDE FOR SUBJECT To SEASONAL OR PERIODIC offorson County Board 'of Comrnisszionexs, in accordance with Title 13-7-101 through may adopt Jefferson County Zoning -BE IT, RESOLVED by t11e..TofforSon Comfy Board of Comn1isSionorS 7 ?ifigoxz County Zoning Rosolutionfind map be: adopted as followsht365Inflr N, VJV II .I Ulzl '1 ha? I rm 1I I'wt" 'xu QNINDZ EIBZ-EBTNUI Nvfififlfififi . . ARTICLE 1 I gin' 'lugThis known 1 can of I <> 1' . I - A home occupation is an activity oonclueted within a dwelling or i 'is accessory, incidental, and subordinate to the principal J9 vtyrelling or property. Type "gt" activities are conducted entirely within are conducted in an attached garage or accessory - lnuilding which has collected scrap, rags, or other discarded I five (5) vehicles or machines which are not in operating condition. . - ltt3"." - if,' I I .li.A It .Wh1Ch collects salvage, scrap, or any type at discarded vw . . . . of salva.ge.matona.ls on the property or of . .. '5l1Gh"Ill:1 .. :5-at 31 into sink holes or trcnohos shall be deemed a, landfill. I I 4 ex and maintenance of trees, shrubs, lawns, and ground cover _t fountains, retaining walls, street furniture, sculptures, or .l - - 5 'tin ta'-accessory may be as landscaping if integrally 'lj?street which collects trafiio from loeal streets and whose adjacent Elan naturedesigned to provide vehieular access to slnutung property and fronts on and has access to public: (governmentally owned and .tti . . "is ooeupied or intended to be occupied by a building or buildings . I - I - i- tando ens noes. .- 1 5| I "will )r . . t, .. lot existing prior to this resolution, the 'ouundaries of which are filed factory built single family structure that tional Manufactured Housing Construction and Safety Act, is and includes factory built single family residential so-uoturu having a . - . attached sides with the ability to attach wheels for highway I i . . 9 . Without a permanent -foundation when oonnested to the required factory built single family rosidennal structure it 5 I ('route sections or pet-xnanontly attached axles with the I Ufa, (bf fly?' "l'n - I ('itlirlt-'if'. Eu. 1 gr"tip . d' I .- In .- 'fig TE/'l'E'cl atsziaszsaa EIMINUZ sa:st ?ttaa--Etta--Hor -$33'-47-wheels for highway transportation, and without a permanent foundation ., . r' - 2 . required unhnesfactory built single farnily residential structure constructed in one or but does not, have permanent nodes with the ability fig; and is constructed on a pennonent foundation when . Iitflities. "rgfl. I I NTLM. DWELLN PARK OEILE HOME PARK. . A five 1' Iland under single ownorohip, that has been planned and improved as EL Plann in section 7 .4, for the placement of a minimum of five (providing health services primarily for human in-patient medical I. -4 . f, injured and including related facilities such as laboratories, out-paficnt . . I medical services, and staff offices whiolmre an integral part of the II I. . I '15' -- . I I, 'Ii'-ten A fac111ty unlined by a health unit for the provision Any structure or land lawfully oeoupzed by a use that does not . -I . -- which it '5 situated(In ga.seous,11qu1d, solli Particulate, or any other form) winch is TE: 3 a to living organisms, chemical reactions, or detrimental effects upon well-being of Indxvidualspnvately owned In which a medical doctor.3-an advanced practice nurse, ondior 3, physician assistant pain . patients, a mag" ority of Whom are iosuod a prescription for, or are . 7 jdiiazjepinc, barbiturates, on carisoprodoi, but not including suhonone, for 1 - .Itw?1y?(12) month period. {flesolutzon 201.2-12'B5tabl1shIneI1ts In services involmng the I . I. at 3' I apparel, such as beauty and barber shops, shoe repair, tailor Iylnland exercise salonscoir; ,1 Milt' 3% . I -, Iii? I I 9' i I in' 4'51'iimm.5: Iain'cl BNINDZ SE :91? - - at'; so - - - . -.4: A .. - -..--. - (-5131fin'--F 'h in.' . tlfiiw I . tn}, it-. . it-orcobinsticn of uses which is professionally clesiged to allow I sits and building location, in accordance with a plan 4' :v~e-rA I 2' . 'ls'-'Rt .. .nh?WnPW"w"MmM~ . primary purpose for which land or a building is used. 1 1 v. 5' E. "l?gi a' IC . engaged in selling goods and/or offering 4 W. for personal, small business, or household use or consumptionearth station antenna, parabolic or spherical design, for the . . . eeceptn 3 the satellite or terrestrial scrviccs. the purpose of this ordinance, is shopping center shall be considered -as If single parcel of property which is internally separated or segregated into i' . separate, distinct functions. Individual ownership is not :1 ii 1' Hf -H. considered as planned unit developments. I I '1 iilenircc, structure, or natural feature or part theigeof, which is used to attract ?i:isf,for the: purpose of communicating a message by any means, including Flsymbols, fixtures, colors, or piojected images- I . cf sign are the following types ofsigcs. ., .. .. 4 me, If, (nu, ,1 JVWI i . .. Any sign intended to he hung either with or without frames, possessing illustrations, or ornan1entat_ion's epplied to pepcr, plastic, or fabric of flags, flags of political subdivisions, and symbolic flags considered banners for the pinpose of this ordinance. IL I: . . :4 -'1-r-nun tug}, isms' sigmlocaied on any part of the surface of a bench or seat placed on or -1. - QFEPREMISE SIGN. A non-point~of-sale sign which advertises a :lcii\dn, event, person, place, or timing, unless such sign is more . 3, I I hl - ed herein. 'hm A 1 . nu.' . fl,' i A A sign that is designed so that illustrations can bc changed or without altering the face . <> nI . - two non-residents of the dwelling are allowed. I. I 3 - safe. -P -- .. .2 - ..-2 - - .9- . 414.4. 'Billboards. Sign and billboards shall be permitted in commercial, . ..-N in . . . . districts. The height of such Slgilfl shall not exceed fifty (50) feet in 1 height pit' ifept. in area. ,No flashing signs or other signage shall be permitted Within . residential district or a.Irosideni;iaI stincture. No signs shall be II I or county right-of-ways. "For sale" sigs, not exceeding twentyfive 'spennitted'Iin'residential disnidts. Auction' sigis shall be permitted I.l.I. vi. lIlI':Ilpg!' %@mWp' . I I . m>>lII . "l"'"410 la' Pu; as . w. s.ii.z.. wt . szunmoz 21:ea--eo--Ner a . I 'i I I IEWA 5,-I.tsan-3I .-. . I ,5 tgoro h1n-Idrod- (200) square foot, and shall 'no removed ten days of 6; I 'l'I I I .- .. tr- no.rnobilo horns park oonsists of five or homo on a lot or lots under the some ownorship. 'Tho follo-. - - . . park shall he fivo.-hundred (500) foot of any rostdenos except ft I I by tho mobtlo home park operator/owner. II fl/rm? I I "i"l1parks wattnn 1,000 foot of any rosrdenoe, that of the park ownor, I . buffer, oornposod of vogotationiivo (5) foot in width and at fang,' I (I IHII . foot tall. The buffer shall be required on any facing such 3 I 'urn'; I (E I. I II II: 'Iul 4:5' Ifmir -I I If 1 Leis" park may be constructsd in which the only access is by residential i recorded subdivision. Mobile homo parks rnust have thirty (30) foot I . to a oout1ty,stato, federal, or city owned road't'Imt:'nl'" fi%'1 tfi . A I I hno must ho provtded to all sttes. A fire hydrant must be up') must..bo to county owned standards. . . -W fivolhundrod foot. . .. .o_v.or fifteen (15) lots must be: on pubho sowor. I I \s 17} 'flli "1 I: I Info': 5" having loss than fifteen units without access to public sows: must in': *1 .I-to {must be approved by the: planning commission prior to any construction. . must include s1to arse, topography, drainage plans, specific parking locations of water or sewer hues, septic systems (where applicable), 0 'Buffering, (accessory buildings such as offices or Laundrornats), parks I ssworago disposal systems approved by the State Department 'g4 Rfigufiq . I *7 may deny the srto plan due to poor s1to design for traffic . I . . I .l 'jiztfifi to at mobtlo home park ontranoo, poor drarnago plans, I of 60 mp1 or gvsator, lack of parkmg, oto. . . .3 . ., ,=uVso -'numn,~ . . <> I . I . .-. will in . . liilgyk litlat one. The purpose of the Planned Unit is to provide for diversification in the relationship of uses and no a . . . . also provide flexibility which will create a more desirable living II was .. ., 13$ . > tilts lm-u' E''.Llal5.\ 1 ED I :l:lD BN1 HCIZ 83 . - . I I - Plan. Prior to submitting a prelirninary Subdivision plat for _a Pl.lD plan. shall be submitted to the planning . which shall rnolnde the following: the general location of 5 and uses, general circulation patterns, openspaoe and recreation . parking areas, ingress/egress points, sketch elevanons and drainage, the overa.l1= densitv of development, public uses, 1- concepts,' zoning classification, and other information deemed - 'rent by the planning commission. The approved preliminary PUD plan as the plan upon which the final PUD plan and preliminary - 1 - I plat are based. Approval of a preliminary PUD plan shall lapse _t - - months fiom on date it was approved. .2 . In addition to meeting the .1 I provisions of the subdivision regulations regarding preparation of a i plat, the final PUD plan shall rnolucle detailed . 'nearing laps for utilities vehioulsr and edestrian locaficljn of all structures, topographic intervalspat no less -. rninimurn elevations, and grading, the physical relatioosltip - oh parking areas, open space and recreation areas, landscaped areas, -I .'or soroeriing materials and locations, areas proposed for dedication as ways, or places, final drafts of legal documents, and other inforination z- pertinent by the planning commission. Upon approval of the final 1 and the preliminary subdivision plat by the planning oornrnission, may commence with the installation of public improvements. .f however, shall he sold until final subdivision plat approval has been .. the planning all required improvements having installed or approrpriatevsoourity posted for the installation of such --is.' :0 -I 'tau 1 '9 79% . In in which no parcel of property is owned or rented, such as eondominium, .-. Inwept, commercial, or industrial PUDs, and similar uses, the following for PUD plan preparation applyPlan, A, concept plan prepared by an architect/engineer 9, the following ixifonnafion shall be sulonritted to the planning I ijigoparnission for review: the general location of buildings and uses, general patterns, open space and recreation areas, parking areas, points, sketch elevations and drainage, the boundary . . . . - . overall density of development, public uses, landscaping I zoning classification, and other infonnation deemed pertinent by the I . a "in. . a - . . commission. The approved prelnninary PUD plan shall serve as the . was, . - 4 "ltd ttfilr which the final PUD plan is based. Approval of preliirnnarv PUD Al 4, I lapse twelve (12) months fl'CIIl1 the date it was approved. 5 'him mlPlan. Following approval of a prslirnmarv FUD plan. themay -proceed to prepare a final PUD plan which shall include "3 . . . - i it-' . -. til, . I I- ll XII ':l'Heh I. Hp.' . I I 7 9 Will?' "Ir-cm --H ii/as-s osmoz east scrip? o- $Wflhi: . . - . . srchitectiiral/engineering plans for: utilities, vehicnlar and pedestrian jfi systems, location of topographic intervals at no less give (5) minimum elevations, and grading, the physical relationship areas, open space and recreation areas, landscaped areas, or screening and locations, areas proposed for dedication as ways,'or places, final drafts of legal documents, and other infoiination I by tlieplanning Upon approval of the final . '-554 a special conditions pennitrnay be issued. '-sit: . 2 4 _Di-rvclo or The PUD applicant may elect to develop the site in Li'; The stages and expected-development periods shall be shown on PUD development plan. However, each stage given final PUD substantially complete within itself. The planning commission may - - 'eadevelopment of a PUD project in stages if public facilities are not . the entire . . . 'ti developer of a PUD shall be entitled to receive appropriate as following appioval of the final PUD plan and the preliminary i, i' it -poplar, where applicable. However, none of these permits shall be issued I"u' In official receives a PUD plan which bears the signed certificates and agreement (See Appeiidnt for examples~-I_uHi I . . . A PUD project may he changed or modified under The planning commission may approve changes in minor shifts ocations proposed streets and ways, utilities and easements, . open space areas or other features on the approved plan. However, i '""rc1ien es .'-sliall not increase densities, cliaii exterior boundary lines, chan is 1 1 . eh-an location or amount of land devoted to 5 ecific uses change the exterior features or appearance of buildings and uses . . approved plans. - -tr "it . . qr}: i ll I tit: A . "ii. All changes other than those established as minor shall he . changes to the PUD plan 'and shall require a new plan - I accordance with the 'pmoed,ures for approval Aptoniobile W-gglij Yards. Dumps, -. -it of the nature and character of their operations, automobile wrecking an I rds, and similar uses of land can have a decidedly detrimental - Wu' "0 '1 I - . upori_-is .1) A gee. Salvage and wreoltmg yards tend to create problems of noise, dust, 'and may adversely affect property values by their general appearance. . .-altMsiiall be used as a guide in evaluating whether proposed land uses, such . as ii' if' properly tlicir objectionable characteristicspar(1.60 1 . . Wt 'Ill I ll 14"' . .-. mi. slum yam, ,I..Qkfi;- - I s, a. "rant ,3 3 mg' 433$: to a I . - tits'Mu, .. ,i I. {Jill irxses owmoz east 2ioa--en-~Ner .. ., - -..- -, "wits . ,4 . EUR13 CW H-H gedds stored or kept in such yards shall be so kept that they will not in which mosquitoes may breed and so that they will not - . i -1: 13-4 -are - .5, 2,pieces in which rats, iniee, or other vermin may be harbored, a sited. "vi -. Vi 2 wswesewosu . . 'uifiss 1 \fi;t1ietendenoy.for salvage yards to promote the breeding of vermin, no such 'aI'fn'Ipermitted closer than five hundred (500) feet from any established I it: er I 4 storage of salvage and wreokmg operations shall be conducted entirely 1-4" II .n if 1 opaque fence, sereeii, or well, excepting driveway areas, fiorii <> 4 I 'if I I yyikf Di5'i'- I 31:' . . - . A. :33? - fig: {Io achieve the intent of th1s the followmg uses are permittedII. IVIH and snmlar acnvmes mcludang. geamral crop farmmga aqua?u1tu1-a, and the processmg andfox sales of agricultural grown, or culnvated onfche premlses--I home: occup anons in aczcgordance with Swtlon 7- . I . - I -s33531135 3m1'33'marl-acts, omn oparatacl mdao rental stores, rfistaurantfia gs,.gronem5I stores, lnufigfififbmfig .4115 fl0?15E3.- l'I II It-'Ir; I .. I II1nc1udIng: barber shops, beauty shops, pedxcurafmanzcure shopstanmng salonsawlodges, and clubsIncluding: Past Offices, Ilibi-a1;ieIsI Bad . . :l3Iv',n33I:|:lCl EJNINEIE :91 --1'lat Wl . I 2' I. I figfig: .. ~1.jI, I Itt,' Isusesinoluding: video game arcades and billiards/pool rooms. .: I In-recreation aosrities including; golf oourses, driving ranges, parks, uv 04' I -2 fields, and playgounds. my . 43,: .ino1udtng: shops that repair watches, jewelry, clocks, shoes, guns, and small engineslinoludingt marinas, travel trailer parks, and veteritrafian offioes. I - - 1, I, use irroluding (see Article indoor firing ranges, outdoor firing shootmg, kennels, offiroad Ire_hIole faoilrties, outdoor ., flea. markets, and bed and breakfast Irma. and are as speoral erroepttons provrded they the requtrements for the 1:1 whroh they are located and . oonditrons, as determtned by the Jefferson County Board of cg,' Appeals, 200991) I ti *1 :1 regulations shall apply only to aircraft as herein defined. Ultra light - I MI -I I I 3, model mrplanes, model helrcopters, model rockets, hot an' balloonsunmanned atrorart are exernpt fiom these.regulattonslocated 111 the A-1 zone, the sue lens for nan' flanpark, plans for the runways, local trafiio pattern, hangars, industrial uses of the aircraft landing field, and other appropriate I ll." Vols,' -: his' I I - I . and doournentatron shall be to the BZA for approval. FL I I, -. proposed or arr park must meet or exceed the requrrsm cuts of any 1, regulations, statutes, laws, ordinances of all local, state, and federal "ha ,1 Inns'. "fl; and ageneres, Including, but not limited to the Federal Admuustrauon. Certtfioatron by an arohrteet, engmeer, or other . design professional that the proposed airstrip, sir park, runway, eto. - jt: or exceeds the requirements of all local, state, and federal goremmental -, <> 51:: hundred (600) feet .. I .: 3' -I. 1 rung j" . '~21 - 4,501 through 6,000 f0e.t-- seven hundred (7 00) feet 1'11." - . the ends of all runway safety areas shall be setback from property .01; runway length. . 4 3,000 feet and underf 0000 hundred (300) feet 1.11 - 1 ., ways 3,001 through 4,500 -- four hundred (400) feet . 'j - 1' ,3 4,501 through 6,000 ?000 -five: hundred (5 00) feet I-1- pl. -1. --.. I . l' 1 . fl and shall be setback from 010 edge of the . 1 7 based on 1:110 lcng-?11 of tha runway or 1" ,1 Jo': *1 110,', - 3,000 ?001 and under - one hundred fi?ty(150} fact 1 .r -53..-. . . i, I gmnwajrs 3,001 through 4,500 feast two hundred (200) feet '1 1 :14 W. - 4,501 through 6,000 feet two hundred fifty (250) feet . . - 001 -.01 '$1,211; runway safety areas shall be located on air park property, at each 0 I .-- - A gfunway, and shall be based .0n- length: . . I II: 35310,". . g: . 3,000 feat and under - three hundred (3 00) feet 3,001 through 4,500 feet few: hundred fifty (450) feet . 4,501 through 0,000 ?00,1- six feet . . 'w . fl .. the: runway must b0 situated 30 that there are no schools, h0us_0s, . R: 0 churches, placas 0:1' publiv. gathezing or other occupied . .- and takeoff arcas. Approach and t0k::0ff ar0as are 3 ends of a nmway that axtand and 05,0 outward.m 11110 With 1:110 appmach and talszaofi argzas by the park 51:. 29 '2 . - EININDZ 12:91 HI I mu('nu I I lJ\\44i?8'd -.-. I .- -- >17'ail . I I - . -. .-- iczuif -discs I I. ll 3" 'ban the length of the runway: I I 'Uri'; '5 . A .I, "'l.5I I '(Iv I I I. IIMI . \ll?l\d WI. \r I . I fifths runway[have an easement controlling ouiiding development in the approach ens. The and widths '0f=fl'IE= required approach and takeoff areas A 3,000 feet and under - one thousand five hundred (1,500) feet iorig and four hundred (400) feet wide at the farthest distance from the end 3,001 through 4,500 feet -- two thousand (2,000) feet and five (500) feet wide at the farthest distance fiom the end of the .-- - . 4,501 through 6,000 feet -- 'two thousand five hundred (2,500) I ";'Cai'I x' six hundred (600) feet wide at the farflicst distance fiorn the end I '1 I runway. . g, Any item not specifically noted alcove, unless tile 30: crson County . .. I nigdippcals dcelns 8. proposed use to a type listed above'rib', II I 9 I - II-I kt' qp Lhinl :"div: II I . I 1&yealffgood utilities, and good access to commercial activitiesand duplexes. I .114' . home occupnuons, In accordance with section 7.1. I I - I A Ifiw"ll235:1) 1- I I In 'gmInf. If"? .1. I "lg I iiyloi I tutu. I I illq WII Al-In. $22must he set back ten (10) feet from the side and rear (30) foot from the front property line. Accessory buildings must he 4 (5) feet from the. side and rear lot lines. No accessory buildings are fiont yards. Signs must be set back five (5) feet from any lot line. sidenti I Dish-'ct. The intent of this district is to establish areas for uses that are adjacent to or convenient to municipalities and to commercial, industrial, and other uses that would intezrfere with the characteristics of the district. The requirements of this district one development of the county by encouraging residential activities achieve the intent of this district, the following land uses are I s'\23;: -(Iii 'as. I I If I Pf" 1.: Illff ,.l'If.IpI' ,1 ffn' ll, IIQII, I. -, Any use not listed above unless the Jefferson County Board of Zoning 4 as that 3. proposed use is similar to one listed above and is Within the I. . . cI;Iing,distrIct125I31 ";IaiqIc;IIaIrda11ceI wIth Section 9.1. I I II wWm' I I fig; InEng-The ., Ign; of the county by encI:Iu;ragmg residcnt1a1,act1II.IIt1es In areas with good wads I I I I access to I::ommI:I:c1a1 actI.vIt1cs. .2012-09lfli; I I II I- A. 32:: -. .I I I. the Intent of th1s the follow: land 11335 are lI:t"I"' |tia1 S111 W3 In U. 331 Hill IS: I II'fil1Inga'tihome occII;Ipat1on5, section 7'Iih uh I II I QJWI nib' Ila"Irinkit-Any use not Iiated above unless the Jsffarsen Ccrunty Board of Zoning that a 1' sad use 15 aamxlar to on: lxsted abova and Imam 'Iv fie,w1th 9.fifig?g f?"?fi3 . <> I:s1'v1ccs cstabli ants Institutions attome: 5 $503ISIS "Is1'hilt'Ely html' 1' '#NEIZ ES :9 I I BE-8-Nbll' . v.4; faincluding: hospitals; medical treatment fetcifitiesg and effiees . dentists, and II _'ters. . fin?' I I "lIices including: barber shops, beauty shops, pedicure/manicure massage therapists, -and tatlning salons'nit- 3:60' I . atto .,ses Including: vrdeo game arcades, btlliarfle/pool rooms, . II I I I skatrng rrIov1e theaters, and finrxg ranges. - - - ree on uses meludrng; golf courses, dnving ranges, parks, and -I, ,_ge~oart tracks, and fairsmcludmg: shops that reparr watches, clocks, shees, guns, enginesincluding: eIrIJrc:hes, eertieteries, and lodges and olubs. of motor vehicles. . LI . .- .- including: airports. kennels, flea msrleets, bed sud breakfast I 'Any use net listed above unless the Jefferson County Board of Zoning -I . I proposed use is one listed above and is within the . ter --sewer square eet. . - .. musewer 20,000 square feet'Ir' I I dm 5, etbeclceFront -forty (40) feet; rear twenty (20) feet; side - water-.s.nd sewer 10,000 square feetWisfeet. i' kl - Ti IlkaInf?' 1 IL I hwy" I I I '-Building: Not permittedin front yards. Must be located ten (10) feet IrI-md rear property huesI'.l'I I I I II 1..st'IIEIPII -.I I-II'in 3..-., . ., . . 9 I 1 1 'qril: Wall! 3 sens EIHINUZ 92:91 2tea--ae--IxIer The intent of this district is to establish areas for industrial .. I I I I good transportatxon faoxlmes and and that W111 not oxghbormg The of fins are de:s1gno-d to I .I I I- Ias aotivimos and usos. CRE.?D3utmn 2012-I1~I;I;sd Uses.' To aohxovo tho 1-ntmt of tins d1str1ct the followmg uses aretiming. I I fin' I 4 I I 2 ssosms I . I 15u"I'ivofrsw mammalsnalsb /(IVII I J, n\ i I . otradeards(figsto1=ago,ofmotorr vohmlosII. prowded no portion of the 1s located closer than one my 4' I I I I: foot to any puhho or pnvato school, day care center, church, or . Ir .. - distnots01:11 a ma be ormmod the Board of Zoom .9 9115type to those uses poxmittod aboveBoard of Zmgun A :2 3,3 ncouous 1n nature and .I-, I I affect the health and safety so the surroun ng proportxesgr-dad. . Irg--:2 -glihadons a:1dPa1n Manage-montC11n1csprov1 . Busmoss Lmensc, s. vahd Corufioatmn by tho State Health Dopartroognt, compliance all spphoablc Jefferson Csusgty and oontmuegl oon1p11s.:1oe With the I Luset forth 1n the SpogI:Lsl 13 msued, I -., -.-I-. "tn t['us:31 SIZE-EIB-NBS -. .1r4~ - 3' 3:3 s. -r 4.E3'l3'cluno or faoIlI,ty shall be located on and have to a otroot I {flu IA . . as 8. Major Collector or Artcnal, as shown on the Jefferson -I I I, II I Major Road Planshowing oxistmg land use and zomng w1th1I:I one-quarter I I- I2. of the proposod site Wifll site plan'With all applmablo of Soct1orI 62-3 8-201 . I52--3 8-210 of the Cage or facillty shall not be located five hundred (500) feet school, day care faomty, park, church or . |u,Q I . I I. I mammum sign area does not exceed twenty (20) square feet in area ., flmoots all .roqu1'roments of Section 1]-604. . I I I Parlung prowded at one (1) space for each five hundred (500) - fcizl: I I I feet offloor space. 6. site sballunot be less than Om: Thousand (1,000) foot fiom any other .toauazxoot chino DIE fao1I1ty. . I ohmo or faoxhty shall not be located wnhm. One Thousand (1,000:41, of aI_1y ostablishmont that Solis aloizshoho hovoragos for o1the:r on-o1Iufifiys: 'Ian . 55' 6 I 5 - -.I may -use not l1stod above unless the: Jefferson County Board of Zomng water and sewer 40,000 square: foot. =11 -I jitglio water or sowor 20,000 square foot.-girluf: IE. Ihr-kwETEIEHLEIESBB . (25) fact. Buflding: Not pexmitted in front yards. Must be located ton 10) foot roar proporty mes. ir Iguvahi mixoto1'.and sewer 510,000 sguaro foot. I Buildging/Istruotoro: Front -- fifiy (50) feet; rear -- twenty-five (25) foot; SN I N02 22 ST I - I .. - 2 IraqmIy@IfimI%mWuIwDistrict. Intent of ta c=sI.ab11sh areas for heavy that m1n1n:I1ze: any advarse effects on propertzes and 2012-11achmve the: Intent the fo1lowII:Ig uses are allowfici. if Id': IvaMil'Iv"gal,g_g -Mrhg' 7" I IIWPI I I "'-far bu:-mug 0 Waste matmals.I. |fi'gin'; I II I I plants where: potentIal1y hazardous che1nIc-.2113 are used or mada. I I, \'ll.lJI' 'flfixnlj' 4 I fin", 2wEURywn?"wVfirIT' 2 . I'above unless the Jefferson County Board of Zomng Appeals s1m:I1ar to one. hated above: and Is w1t111n the Intent "1w%&hNmr>>'x u-\I'fi'I:{.ai5gcm5- . 1- 17* I-MI I I fiuI'~u I . fling Setbacks"It'll I I 1 - a.I'Ihundred (100) feat, rear -- fifty (5 0) I I1-II I . I II flit}? (50) fcct"finfront yards. Must be located Ian (10) feet from -,s?I I I I I I lillf-'1 I I - I. . IH7hilir I-..I I I I I 'I-finfig WIVIJ 531:1-I'll nI<< ar?la 62998 33IddU BNINDZ 22:91 . If I hi I I 'u "wt"ilk [rum 1 Icfii fr 'kl-'h II I . Nfimq,%" "Edsesrt istrict, The intent of this district is to allow and I unit developments, xesoi-ts, hotels, conference centers, and leil-5,r,f-locate in an attractive rural setting witli natural sinenities such as lakes, and other desirable landscape characteristics- It is also the intent of rivers 'mc'un' I this sand to be used and developed in a manner consistent wsii its nsitural 1 natural environment- This iititeut as to lie achieved by uppropnntely . in clustering of buildings, niininiizing the amount (if roadway, and vegetative buffers, landscaping, effective storni water ofl natural drainage ways, good read access to the site, and basing the . . the availability of public 11tl11t1t.'.1S. 2012-07N431111.-1 . . . . . acliieve the intent of this district, the following uses are permitted121activities including: multifamily developments (condominiums, . fies, spaiztnients) and detached s1ng,1e--fsmi1y houses and duplexes filgliey are part of a planned unit development. If .- itfisccessory uses including: resorts, hotels, conference centers, equestrian 1 u' "l a and golf courses. I 1 ll - uses including the following are permitted provided they are within al building or are pent of a planned unit development and 'in total do not '3 K) 1,000 square feet cf property, including parking, for each 'tor tgansient housing unit: . I . gglonvmienee commercial activities including: gasoline service stations, markets, video rental stones, restaurants, drug srocsry lounges/bars, video game arcades, billiards/pool rooms11:35' 2' I I 1 I 1.1' services including: barber shops, beauty shopsfillw. I xv..) shops, 1icensed,niss,snge therapists, and tanning salonsdlied db eskf t' 110111Mobile homes and mobile home recreation vehicles and 's Iu:1-1 -- and any use not mecitieslly identified above unless etennine .fl;mussnd (30 000) square .7 1 7 1'5' fir n' I - Ming setbacks. All buildings must be set back twenty-five feet from ten feet from mtemcr.prcp1e'1'cy 'lines, and 1111111113' 161111111111 Each lye. . I Di "-'Elli lawEININBZ gt; -91; 3-553 8 - - (I -I 7 PH - 7/IfM-ammw I I I4 I mt--.II"wzhlu, .. my, E. . Smflrcmdentlal and uses shall has one umt for 30,000 . . 1; 2 grass acreage. - I I ilhHfi? lug 1 )?'Ilp11'1eI'1tS must have access fiqm pagi-'Gd p1.l.b11G roads that are not 2 -I (139 feet In mamEv' '1qpments must be served by a ,puh1Ic water system Water 111165 (6) mchea 111 dmmeter and have adequate pressure and ,F1re hydrants shall be so that all are w1t111n 500 4 I ., lit" If .- avdraut Er' 1-.0-I In -I I I. 2'1 storm water facilities shall be desigmcl and 30 . I II storm water does not fixceed oftwenty-folxr hour duration. I- - I :1 IdlIlmum height of the Qccupled pomazm hf any hum-ldang shall not exceed vlivl . u\ . I. I was) feet- . I - II . urn-.-- - -.- 'ii a. 2:21, 'in I I f:fl Iv' A ST TION fig-2.- I 3, . i I-II. in. .u (ffifised by K350195103 2003*": adopted A . . aimed tp issue all permits, mamtam and forward matenals I.., 3 II I. I . I the plannmg com:;mss1on. The. zamng offimal shall routmely publifibodics. Cultrent mpniilg illaps axlfl map shall and he: shall qnnduct lnfipfictlfinfi as prescnbad by fins -ll I 1- ll.- #5 -.2 1 Fe II, its (rwised by Resolution 200044, adopthd l0- :3 start const1'uction of an principal building or accessory _?i:m1ned. It. Shall also be: unlawfill to consthuct add1_t1o_ns 1.0 211?; .3 it i?\Obmmed_ nq zanmg perm: ordinary huilI.-ling Inaiht?nauce or repair. n0d2<;n1FD% shall be rcaquxred forhtha ('sf Intelrfiikt .l -. II 9. ufi BNINEIZ 22:91 2Iaa--aEI--r~Iur - I I I 'n'll'i'"tlrug-I! I I-compliance/building poxmit shall he denied when the proposed 'dfl1'aI:Id use which is not allowed in that zoning dismiot, when the setbacks cannot Iother typo of vzolanon of the re.-gulatxons 111 zomng rI=:so1utIon. The I I I l""v . ., . relovant dctafls of construction and comfy on tho pemut that the I - I . A stop work order may be issued on oo11sn-uction or land usago . I1-noces a,zoning violation. All work must thorein desist until the .1 . I The zoning oomplianocfbuilding permit is valid for six (6) months after I . I. I if consuucfion on the projeofi site is not p1'ogvossing. 'finy porson found violating the of this rcsohrrion shall be .-1 Egaggor, and upon conviction 'Shall be fined not less than fivc (5) dollars do . . (50) dollars per (Lay. - Le. (a,I1I1ecI.by Resolution 2000-44, adopted Io-16-00). The following .;fij;:'?56 I Ego ;?;i?IIobi1e and modular homes. $300 base fee plus $3 for eaolu $1,000 of valuation and .323', 5.: . I-Iousi I $25 basefe:op1us$3 for each $1,000 ofvaluataon penmt fees are doubled }J,1_1o homco 13 $300 per linear foot and new r.nob11o home valor-moms are I, ffiifonnation. All other valuauons are based on "Buxlding Valuatxon DataAvexgages that are puJ:I11shed quarterly by the Southom - '53pig' i 'gay: I . $115 If"! 521' fl"II"ufig'. I 3' I I in4.3-'I-Iwa I3"cl ZTBEILEESBB EDI :l:ICl EIH I NCIZ SE $12 WWI I LI . IJ ,1 513/0' "aw Ir 'fit IIEA lhqv5:33, The Board of Zomng Appeals shall be creafiad and appcunted awn,' ed, Secuuns 13-7-I106 and13~7*107Any person, adjacent property owner, or govegnme-Intal unit may Appeals for spec1aI exoeptions, vanancgs, and a11aga'r.1ons tha I I . . end or fafleacl ta issue a .3 . I an 331' an caved erscm Boa . The of Appeals in 333requasnng a spasmmal zon1:I3.g d1.str1'ct or a charamueii . I - :1 was 1'6 PermifigiiSeamanwmqham thirty (30) days after a requzzft 'Zomng Appeals, a pubhc: mam' nIg shouid be 6 d. I 'ii: I .7 I I dgcifiw, I - be conta1ned1n the mmutcs of ame:ct1I1E.-I, I I Ifauh I . - 1' xxnu'-'1'5: 'il'T'"'l4i lift ('#nun'I-I1. fle-I, Ivtilu in'away I. I,,r..wIu . BILLEESBB ED I FJN I NCIZ SE ST I I amo;o'dn'l I I 11 Board; I ouhli (ltfi f' 1 1 11 uu I ll'; $3 31 of. i8fions. The amendment shall ho offocfivo upon the majority voto of approval :?1411 ill' Ii'url I oilIf," lb} fl I sol if '~nlar I 1'1 1' '1 ,2 *1 J-"ll 1 54 1.11 1535+ I 1 I If A nu"; )4 I II Irfiiatl - '9c'..1i.E5 2998 I . I - . ll; ARTICLE 12 1 'l Ii' -s ATIO This resolution may be: by first submitting a proposed map to the planning commission and than to tho Jefferson County I Commissioners. A public hearing must bo called at least thirty (30) -the hearing on any amondnsont by tho county commissioners, and this in a. local nowspapopof general I.-iroulation in the: county. . "I'llWhore other state or local laws are in oonfliot, the more strings-nt 1. Should a. section, clause, or provision of this resolution be declared I juoisdiotioo, or uncorrsiitufrional, tho judgm out shall not affect the wholo or any port other than the port judged to be my slid. *2 I 'lI 1 :'r-as-1 4 I lilo: 553ilkammo: 92:91: 2Ioa--so-Nor 1,11 1, llraw,' 1 ,1\v11 II11 34 I I - 1'4twfilfil #15 1\."lfi I114QIIWV 9 'f man" fi:.May 111'11. *1 1" I lm1M'fI*1-s1I'13. Hp. .. I rI!.171 11 1 1, 11I,1\m; 1 I 4' I T711 htIP14 I111.('issicna I . .1 IS I IJJII figM11115 1, 1 '2 -1, 1' I I-I31 1 . If>> ,5 h'1' I I, _l 11 (1)1 1 I I Way1xJryfilfil . -4111 1I1I1 1I 1 14;. . 1 1'f{1151I'llLinI\?1Ll1w1., Ii,r1,1 I 73 I 5.1! L11 1.I 'c1.1I>>glam Ink . ufir Iwmh 9871:! .-45,4 big'! '<