The Result of Government Gone Mad. This is still going on. These are the same officials who I took to Court and they simply ignored it and nobody made them.
Motion To Dismiss Raanan Katz Copyright Lawsuitrkcenters
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Miami Heat minority owner Raanan Katz does not appreciate the photo of himself circulating on the internet, so he is suing Google and a Miami blogger for refusing to take it down.
And Raanan Katz, RK Centers Owner, apparently has enough money to sue anybody else who posts the photo.
Motion To Dismiss Raanan Katz Copyright Lawsuitrkcenters
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Miami Heat minority owner Raanan Katz does not appreciate the photo of himself circulating on the internet, so he is suing Google and a Miami blogger for refusing to take it down.
And Raanan Katz, RK Centers Owner, apparently has enough money to sue anybody else who posts the photo.
Answer, Counterclaims & Third Party Claims - Non-Compete & Tortious InterferencePollard PLLC
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This is one of our cases in Volusia County, Florida. Our clients - all of the defendants in the case - were sued for breach of a non-compete agreement, breach of fiduciary duty and tortious interference.
We responded with counterclaims for a declaratory judgment holding the non-compete agreement(s) unenforceable, third party claims for breach of fiduciary duty and breach of contract and a demand for indemnification.
This is a good example of our level of work. We have extensive experience litigating non-compete and tortious interference cases on both sides. We prosecute and defend these types of cases.
In every case, we have a process: First, we master the facts. Many lawyer and law firms get involved in a case and immediately focus on law. In our view, that is the wrong approach. All cases are driven by facts. Any legal strategy must be tailored to the specific facts of a specific case.
We do not take anything for granted. We do not default to the same tired boilerplate pleadings. In every new case, we fashion a specific strategy for that case.
If you have a non-compete or tortious interference case, just give us a call at 9543-32-2380. That's what we're here for.
Intervenor Opposition to DEQ motion for Entry of Consent JudgmentJ. Patrick Lucas
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Filed with the court 2/21/2012 is our motion in opposition of the DEQ entry of a consent judgment regarding Frontier Leather and Ken Foster Farms in Sherwood, OR
National Association of Realtor Encourages Diversity in Housing in the areas of Zoning, Code Enforcement and Economic and Community Development. This is a Brief Toolkit to get Residents and Leaders Thinking.
Hootsuite: Maintaining multiple social media accounts Brian Huonker
ย
When it comes to brands on social media, one of the most common mistakes made is not listening to their social following. Many brands choose to promote content and chat via these channels, without having a strong understanding of what their audienceโs preferences and interests actually are.
In short, social listening is a way brands can monitor conversations being held on social channels, in order to identify opportunities to develop, promote, and participate in the discussions through engagement.
To enable this form of customer engagement, brands must be able to identify specific keywords and phrases relevant to their business. For example, with Pepsi, keywords would consist of โsoda, fizzy drink, soft drink etc. Likewise, if you were a service offering company, you may want to monitor conversations surrounding the area your service is in; consequently allowing you to provide your expert input and reach out to the individuals in need of help or advice.
In order to develop a social media listening program, this workshop will utilize Hootsuite and show you how to:
Set up your account
Create your listening streams
Familiarize yourself with analytics
Communicate monitoring goals through conversations
Monitor while on the go
Keep your accounts secure
Several members of the Indianapolis City-County Council, as well as the city-county council clerk who was fired last week by Council President Stephen Clay, are taking him to court.
Answer, Counterclaims & Third Party Claims - Non-Compete & Tortious InterferencePollard PLLC
ย
This is one of our cases in Volusia County, Florida. Our clients - all of the defendants in the case - were sued for breach of a non-compete agreement, breach of fiduciary duty and tortious interference.
We responded with counterclaims for a declaratory judgment holding the non-compete agreement(s) unenforceable, third party claims for breach of fiduciary duty and breach of contract and a demand for indemnification.
This is a good example of our level of work. We have extensive experience litigating non-compete and tortious interference cases on both sides. We prosecute and defend these types of cases.
In every case, we have a process: First, we master the facts. Many lawyer and law firms get involved in a case and immediately focus on law. In our view, that is the wrong approach. All cases are driven by facts. Any legal strategy must be tailored to the specific facts of a specific case.
We do not take anything for granted. We do not default to the same tired boilerplate pleadings. In every new case, we fashion a specific strategy for that case.
If you have a non-compete or tortious interference case, just give us a call at 9543-32-2380. That's what we're here for.
Intervenor Opposition to DEQ motion for Entry of Consent JudgmentJ. Patrick Lucas
ย
Filed with the court 2/21/2012 is our motion in opposition of the DEQ entry of a consent judgment regarding Frontier Leather and Ken Foster Farms in Sherwood, OR
National Association of Realtor Encourages Diversity in Housing in the areas of Zoning, Code Enforcement and Economic and Community Development. This is a Brief Toolkit to get Residents and Leaders Thinking.
Hootsuite: Maintaining multiple social media accounts Brian Huonker
ย
When it comes to brands on social media, one of the most common mistakes made is not listening to their social following. Many brands choose to promote content and chat via these channels, without having a strong understanding of what their audienceโs preferences and interests actually are.
In short, social listening is a way brands can monitor conversations being held on social channels, in order to identify opportunities to develop, promote, and participate in the discussions through engagement.
To enable this form of customer engagement, brands must be able to identify specific keywords and phrases relevant to their business. For example, with Pepsi, keywords would consist of โsoda, fizzy drink, soft drink etc. Likewise, if you were a service offering company, you may want to monitor conversations surrounding the area your service is in; consequently allowing you to provide your expert input and reach out to the individuals in need of help or advice.
In order to develop a social media listening program, this workshop will utilize Hootsuite and show you how to:
Set up your account
Create your listening streams
Familiarize yourself with analytics
Communicate monitoring goals through conversations
Monitor while on the go
Keep your accounts secure
Several members of the Indianapolis City-County Council, as well as the city-county council clerk who was fired last week by Council President Stephen Clay, are taking him to court.
Compilation of Judgments wherein it is held that "Suit is not maintainable"Legal
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Compilation of Judgments of Hon'ble Supreme Court of India and High Courts, wherein it is held that "Suit not is maintainable". This document will be helpful for those who are looking for a complilation of judgments whrein it is held that "Suit not is maintainable" on the one ground or the other.
RK Associates, Raanan Katz Were Alleged In Unlawful Ejectment In Miamirkcenters
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Defendants do not dispute, that security guards threw Plaintiffs off the property and that RK Associates and MWI changed the locks on the bank branch's office doors. Furthermore, Plaintiffs allege conversion of their remaining personal property by RK Associates and MWI after they were escorted from the premises. Judging from the record, the Court finds that there is a possibility that Plaintiffs can establish a cause of action against the resident defendant. Triggs, 154 F.3d at 1287. At the very least, Plaintiffs have a possibility of stating a viable cause of action against the landlord RK Associates for conversion of their equipment and for unlawful ejectment. Defendants themselves note that joinder is deemed legitimate when such possibility exists.
The U.S. Department of State (DOS) agreed to implement new procedures designed to ensure the fair and prompt review of U.S. passport applications by Mexican Americans whose births in Texas were attended by midwives.
The procedural changes were the result of a settlement agreement following a class action lawsuit filed by a coalition of civil rights and legal organizations including the American Civil Liberties Union, the ACLU of Texas, the international law firm Hogan & Hartson LLP, and Refugio del Rio Grande, Inc.
Newtown Loses By Default Judgment- NECA -vs- KaaihueAngela Kaaihue
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Newtown Loses By Default Judgment- NECA -vs- Kaaihue, a five year litigation and court battle. When NECA board of directors, and community are jealous for driving right by a property that could have been purchased, but was inherited by Angela Kaaihue, who has turned the property she inherited into a Hawaiian Gold Mine.
Hawaii Appellant Court Supreme Court judge castegnetti, judge jeffrey crabtree, judge karen t. nakasone, judge katherine g. leonard, judge keith hiraoka, judge lisa m. ginoza, judge sonja mccullen, judge clyde j. wadsworth, judge karen holma, judge gary W.B. chang
Supplemental findings to the worst case conditions analysis for cities and persons living with disabilities. The essential summary and quick point statistics and guidelines ignored by the City of Erie entirely, abused, covered up and the case for a State Level Investigation into the City of Erie Incorporated as being at best an incompetent and corrupt City in need of drastic state intervention on all levels to fine, prosecute, imprison; the need of an Harrisburg Commission into criminal activities and need for temporal State Custodial Administration of the City of Erie.
The latest HUD Comprehensive Analysis of the City of Erie following from Census Results conducted on 2000. The Report describes the challenges, issues, statistics, demographics and various other distributions. Although Variables have been Enormous, we do have preliminary raw data from the 2010 Census. It is a very clear picture of the decay, population dispersion, growth of Government coinciding with Growth in Poverty, Opposite effects in Housing Values, Ownership rates, sustainability and overall indicator or "last checkup". The Results show nothing less than an explosion of non sustainable, rapid, ugly looks into the prospects of Pennsylvania's Poorest City.
Victoria House Closed For Business. Thank You & God Bless.Rob WFlag
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Wishing all the best in all future endeavors and thanking everyone who have helped to make it possible for us to pursue the American Dream. God Bless and Wishing All Prosperous Days. Thank You. Robert E. Widing III.
This was my dog Chili. She was great. I was so busy at the time when I found out she died, it was like a month later when it sunk in. For some reason the Dog was the one constant in my chaotic life. This year has been really rough, it was tough on her anniversary.
When a Utility company attempts to strong arm you (if you lose your job, are disabled, a personal carer or anyone else on a low income and easily susceptible to economic hardship.)
A Checklist from the Public Utilities Commission. Know your rights when dealing with these companies. They prey on the weak and have no low. They would rather push a button and have someone come to your door, in violation of the law, than look up a definition.
My little presentation of the "Beatitudes" (Some of them) in relation to some of the places, people and Revolutionary Brothers in Struggle against the Hive of Political Corruption, negligence, false prophets, communists and tax payer wastage fueling the Machinery of backdoor deals and flat out illegal activities spanning all levels of Government in The City of Erie, Perhaps the County, yet that's not my battle. Just the City, it must come back into Union with the United States of America, apply just law in compliance with the Constitution of the United State of America, with Liberty and Justice for All and have those whom have created the abomination that is "The Peoples Republic of Erie", be brought to Justice for keeping the Citizens of this City in perpetual Poverty, Keeping the Same Ruling Elite in Power by swapping jobs, positions, titles etc; for the last 30 years. Or, they can just give me the damn permit and apologize. Crap I don't care; and LOWER MY PROPERTY TAXES! Please....
Taurus Zodiac Sign_ Personality Traits and Sign Dates.pptxmy Pandit
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Explore the world of the Taurus zodiac sign. Learn about their stability, determination, and appreciation for beauty. Discover how Taureans' grounded nature and hardworking mindset define their unique personality.
RMD24 | Retail media: hoe zet je dit in als je geen AH of Unilever bent? Heid...BBPMedia1
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Grote partijen zijn al een tijdje onderweg met retail media. Ondertussen worden in dit domein ook de kansen zichtbaar voor andere spelers in de markt. Maar met die kansen ontstaan ook vragen: Zelf retail media worden of erop adverteren? In welke fase van de funnel past het en hoe integreer je het in een mediaplan? Wat is nu precies het verschil met marketplaces en Programmatic ads? In dit half uur beslechten we de dilemma's en krijg je antwoorden op wanneer het voor jou tijd is om de volgende stap te zetten.
Business Valuation Principles for EntrepreneursBen Wann
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This insightful presentation is designed to equip entrepreneurs with the essential knowledge and tools needed to accurately value their businesses. Understanding business valuation is crucial for making informed decisions, whether you're seeking investment, planning to sell, or simply want to gauge your company's worth.
"๐ฉ๐ฌ๐ฎ๐ผ๐ต ๐พ๐ฐ๐ป๐ฏ ๐ป๐ฑ ๐ฐ๐บ ๐ฏ๐จ๐ณ๐ญ ๐ซ๐ถ๐ต๐ฌ"
๐๐ ๐๐จ๐ฆ๐ฌ (๐๐ ๐๐จ๐ฆ๐ฆ๐ฎ๐ง๐ข๐๐๐ญ๐ข๐จ๐ง๐ฌ) is a professional event agency that includes experts in the event-organizing market in Vietnam, Korea, and ASEAN countries. We provide unlimited types of events from Music concerts, Fan meetings, and Culture festivals to Corporate events, Internal company events, Golf tournaments, MICE events, and Exhibitions.
๐๐ ๐๐จ๐ฆ๐ฌ provides unlimited package services including such as Event organizing, Event planning, Event production, Manpower, PR marketing, Design 2D/3D, VIP protocols, Interpreter agency, etc.
Sports events - Golf competitions/billiards competitions/company sports events: dynamic and challenging
โญ ๐ ๐๐๐ญ๐ฎ๐ซ๐๐ ๐ฉ๐ซ๐จ๐ฃ๐๐๐ญ๐ฌ:
โข 2024 BAEKHYUN [Lonsdaleite] IN HO CHI MINH
โข SUPER JUNIOR-L.S.S. THE SHOW : Th3ee Guys in HO CHI MINH
โขFreenBecky 1st Fan Meeting in Vietnam
โขCHILDREN ART EXHIBITION 2024: BEYOND BARRIERS
โข WOW K-Music Festival 2023
โข Winner [CROSS] Tour in HCM
โข Super Show 9 in HCM with Super Junior
โข HCMC - Gyeongsangbuk-do Culture and Tourism Festival
โข Korean Vietnam Partnership - Fair with LG
โข Korean President visits Samsung Electronics R&D Center
โข Vietnam Food Expo with Lotte Wellfood
"๐๐ฏ๐๐ซ๐ฒ ๐๐ฏ๐๐ง๐ญ ๐ข๐ฌ ๐ ๐ฌ๐ญ๐จ๐ซ๐ฒ, ๐ ๐ฌ๐ฉ๐๐๐ข๐๐ฅ ๐ฃ๐จ๐ฎ๐ซ๐ง๐๐ฒ. ๐๐ ๐๐ฅ๐ฐ๐๐ฒ๐ฌ ๐๐๐ฅ๐ข๐๐ฏ๐ ๐ญ๐ก๐๐ญ ๐ฌ๐ก๐จ๐ซ๐ญ๐ฅ๐ฒ ๐ฒ๐จ๐ฎ ๐ฐ๐ข๐ฅ๐ฅ ๐๐ ๐ ๐ฉ๐๐ซ๐ญ ๐จ๐ ๐จ๐ฎ๐ซ ๐ฌ๐ญ๐จ๐ซ๐ข๐๐ฌ."
What is the TDS Return Filing Due Date for FY 2024-25.pdfseoforlegalpillers
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It is crucial for the taxpayers to understand about the TDS Return Filing Due Date, so that they can fulfill your TDS obligations efficiently. Taxpayers can avoid penalties by sticking to the deadlines and by accurate filing of TDS. Timely filing of TDS will make sure about the availability of tax credits. You can also seek the professional guidance of experts like Legal Pillers for timely filing of the TDS Return.
Buy Verified PayPal Account | Buy Google 5 Star Reviewsusawebmarket
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Falcon stands out as a top-tier P2P Invoice Discounting platform in India, bridging esteemed blue-chip companies and eager investors. Our goal is to transform the investment landscape in India by establishing a comprehensive destination for borrowers and investors with diverse profiles and needs, all while minimizing risk. What sets Falcon apart is the elimination of intermediaries such as commercial banks and depository institutions, allowing investors to enjoy higher yields.
Explore our most comprehensive guide on lookback analysis at SafePaaS, covering access governance and how it can transform modern ERP audits. Browse now!
As a business owner in Delaware, staying on top of your tax obligations is paramount, especially with the annual deadline for Delaware Franchise Tax looming on March 1. One such obligation is the annual Delaware Franchise Tax, which serves as a crucial requirement for maintaining your companyโs legal standing within the state. While the prospect of handling tax matters may seem daunting, rest assured that the process can be straightforward with the right guidance. In this comprehensive guide, weโll walk you through the steps of filing your Delaware Franchise Tax and provide insights to help you navigate the process effectively.
Premium MEAN Stack Development Solutions for Modern BusinessesSynapseIndia
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Stay ahead of the curve with our premium MEAN Stack Development Solutions. Our expert developers utilize MongoDB, Express.js, AngularJS, and Node.js to create modern and responsive web applications. Trust us for cutting-edge solutions that drive your business growth and success.
Know more: https://www.synapseindia.com/technology/mean-stack-development-company.html
Enterprise Excellence is Inclusive Excellence.pdfKaiNexus
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Enterprise excellence and inclusive excellence are closely linked, and real-world challenges have shown that both are essential to the success of any organization. To achieve enterprise excellence, organizations must focus on improving their operations and processes while creating an inclusive environment that engages everyone. In this interactive session, the facilitator will highlight commonly established business practices and how they limit our ability to engage everyone every day. More importantly, though, participants will likely gain increased awareness of what we can do differently to maximize enterprise excellence through deliberate inclusion.
What is Enterprise Excellence?
Enterprise Excellence is a holistic approach that's aimed at achieving world-class performance across all aspects of the organization.
What might I learn?
A way to engage all in creating Inclusive Excellence. Lessons from the US military and their parallels to the story of Harry Potter. How belt systems and CI teams can destroy inclusive practices. How leadership language invites people to the party. There are three things leaders can do to engage everyone every day: maximizing psychological safety to create environments where folks learn, contribute, and challenge the status quo.
Who might benefit? Anyone and everyone leading folks from the shop floor to top floor.
Dr. William Harvey is a seasoned Operations Leader with extensive experience in chemical processing, manufacturing, and operations management. At Michelman, he currently oversees multiple sites, leading teams in strategic planning and coaching/practicing continuous improvement. William is set to start his eighth year of teaching at the University of Cincinnati where he teaches marketing, finance, and management. William holds various certifications in change management, quality, leadership, operational excellence, team building, and DiSC, among others.
[Note: This is a partial preview. To download this presentation, visit:
https://www.oeconsulting.com.sg/training-presentations]
Sustainability has become an increasingly critical topic as the world recognizes the need to protect our planet and its resources for future generations. Sustainability means meeting our current needs without compromising the ability of future generations to meet theirs. It involves long-term planning and consideration of the consequences of our actions. The goal is to create strategies that ensure the long-term viability of People, Planet, and Profit.
Leading companies such as Nike, Toyota, and Siemens are prioritizing sustainable innovation in their business models, setting an example for others to follow. In this Sustainability training presentation, you will learn key concepts, principles, and practices of sustainability applicable across industries. This training aims to create awareness and educate employees, senior executives, consultants, and other key stakeholders, including investors, policymakers, and supply chain partners, on the importance and implementation of sustainability.
LEARNING OBJECTIVES
1. Develop a comprehensive understanding of the fundamental principles and concepts that form the foundation of sustainability within corporate environments.
2. Explore the sustainability implementation model, focusing on effective measures and reporting strategies to track and communicate sustainability efforts.
3. Identify and define best practices and critical success factors essential for achieving sustainability goals within organizations.
CONTENTS
1. Introduction and Key Concepts of Sustainability
2. Principles and Practices of Sustainability
3. Measures and Reporting in Sustainability
4. Sustainability Implementation & Best Practices
To download the complete presentation, visit: https://www.oeconsulting.com.sg/training-presentations
Accpac to QuickBooks Conversion Navigating the Transition with Online Account...PaulBryant58
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This article provides a comprehensive guide on how to
effectively manage the convert Accpac to QuickBooks , with a particular focus on utilizing online accounting services to streamline the process.
Accpac to QuickBooks Conversion Navigating the Transition with Online Account...
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Complaint, Etc For Email To Complainant
1. IN THE ERIE COUNTY HUMAN RELATIONS COMMISSION<br />ROBERT E. WIDING III, VICTORIA)<br />HOUSE COLLABORATIVE LLC, and)Docket No. 10-002-H<br />JOHN DOES ONE THROUGH FIVE)<br />(Other Current and Prospective)<br />Residents of 1156 West 11th Street),)<br />)<br />Complainants and Plaintiffs)<br />)<br />)<br />)<br />CITY OF ERIE ZONING HEARING )<br />BOARD; CITY OF ERIE, BUREAU OF )<br />CODE ENFORCEMENT; and CITY)<br />OF ERIE,)<br />)<br />Respondents and Defendants)<br />COMPLAINT<br />JURISDICTION<br />Jurisdiction is pursuant to the Erie County Human Relations Commission Ordinance No. 59, 2004, Article V, Section D and Article VI, Section A (as amended by Ordinance No. 39, 2007).<br />PARTIES<br />The Complainants herein are:<br />Name:Robert E. Widing III<br />Address:1156 West 11th Street<br />Erie, PA 16502<br />Name:Victoria House Collaborative LLC<br />Address:1156 West 11th Street<br />Erie, PA 16502<br />and<br />Names:John Does One Through Five (Other current and prospective <br />residents of 1156 W. 11th Street)<br />Address:1156 West 11th Street<br />Erie, PA 16502<br />The Respondents herein are:<br />Name:City of Erie Zoning Hearing Board<br />Address:626 State Street<br />Erie, PA 16501<br />Name:City of Erie, Bureau of Code Enforcement<br />Address:626 State Street<br />Erie, PA 16501<br />and<br />Name:City of Erie<br />Address:626 State Street<br />Erie, PA 16501<br />COUNT 1<br />Denial of Zoning Variance Request/Disability Discrimination<br />Failure to Make Reasonable Accommodation/<br />Disparate Treatment<br />Paragraphs 1 through 3 are incorporated herein by reference as though set forth at length.<br />The Complainants, Robert E. Widing III and John Does One Through Five, jointly and severally aver that their protected class is that of disabled individuals, as delineated and defined under the Erie County Human Relations Commission Ordinance No. 59, 2004 (as amended by Ordinance No. 39, 2007).<br />The Complainant, Victoria House Collaborative LLC, avers that it is a domestic limited liability corporation, incorporated under the laws of the Commonwealth of Pennsylvania, and doing business at all times relevant to this Complaint in Erie County, Pennsylvania.<br />The Complainant, Victoria House Collaborative LLC, avers that it is the successor of Victoria House LLC, which requested certain variances from the Respondents related to the property located at 1156 West 11th Street in Erie, PA, in April and August of 2009.<br /> The Complainant, Victoria House Collaborative LLC, avers that it owns and operates a Group Home, known as โVictoria House,โ located at 1156 West 11th Street in Erie, PA (hereinafter referred to the โpropertyโ).<br />The Complainant, Robert E. Widing III, avers that, in addition to being a disabled individual and resident of Victoria House, he is also the Property Manager/House Manager/Responsible Agent of/for the property. <br />The Complainants aver that Respondents meet the definition of โpersonโ as such term is delineated and defined under the Erie County Human Relations Commission Ordinance No. 59, 2004 (as amended by Ordinance No. 39, 2007).<br />The Complainants aver that, on or about April 28, 2009, they requested the Respondents to grant a variance of the Zoning Ordinance for the City of Erie, Ordinance Number 80-2005 (hereinafter referred to as the โCity Zoning Ordinanceโ) as a reasonable accommodation to allow them to operate and reside in a Group Home related to their disability.<br />The Complainants aver that Section 305.01 of the City Zoning Ordinance provides for a variance/zoning exception for Group Homes such as Victoria House.<br />The Complainants aver that the Respondents denied their initial request for reasonable accommodation on or about May 8, 2009, mischaracterizing Victoria House is a โhalf-way houseโ and/or โrooming houseโ (which Respondents stated are not permitted uses in an R-2 zoning district) and stating that Victoria House is a โhalf-way house without any formal oversight or supervision.โ<br />The Complainants aver that they filed an appeal with the Respondents, asking the Respondents to reconsider the initial denial of the request for the zoning variance/special exception as a reasonable accommodation related to their disability.<br />The Complainants aver that the Respondents held a second hearing on the Complainantsโ request for reasonable accommodation on or about August 25, 2009.<br />The Complainants aver that, in the second hearing, the Respondents acknowledged that Victoria House is, in fact, a โGroup Homeโ that would be covered under the โGroup Home Special Exceptionโ of Section 305.01 of the City Zoning Ordinance.<br />The Complainants aver that the Respondents denied their second request for reasonable accommodation on or about September 8, 2009, stating that density control for a lot size in an R-2 district (3,000 square feet) allows one or two families or three unrelated people only on a lot that size and that the same standard should apply for disabled people as does for non-disabled people.<br />The Complainants aver that the reasons stated by the Respondents for the denial of their request for reasonable accommodation in both the denial of May 8, 2009 and the denial of September 8, 2009 are purely pretext.<br />The Complainants aver that any other reason given by the Respondents for the denial of the requested reasonable accommodation is purely pretext.<br />The Complainants aver that the actual reason that the Respondents denied their request for reasonable accommodation in the form of the zoning variance/special exception is solely because of the Complainantsโ disability and the bias of the Respondents against those with their particular disability.<br />The Complainants aver that any reasonable accommodation made by the Respondents relative to allowing the zoning variance/special exception for Victoria House to operate on the property would not pose an undue hardship on or fundamentally alter the nature of the zoning ordinance.<br />The Complainants aver that there are only six (6) current or prospective residents of Victoria House and that allowing two (2) families of non-disabled persons to live on one property in an R-2 zoning district could easily mean that more than six (6) people would be residing on such property at any given time.<br />The Complainants aver that allowing six (6) unrelated persons to live in one property in an R-2 zoning district as a reasonable accommodation due to their disability does not place any more of an undue hardship on or fundamentally alter the nature of the zoning ordinance than would allowing six (6) related persons to live on the same sized property. <br />The Complainants aver that the property is, in fact, LARGER than the 3,000 square feet required for the R-2 zoning district and that the Respondents are aware, or should be aware, that the property is larger than 3,000 square feet.<br />The Complainants aver that others outside their protected class are treated differently than they have been treated by the Respondents.<br />The Complainants aver, by way of example, that the Respondents have granted zoning variances to other Group Homes under the same or similar circumstances, such as the Gertrude Barber Center and the City Mission.<br />The Complainants aver that others, with no disability and/or with different disabilities than they have are treated more favorably by the Respondents than the Complainants have been treated.<br />The Complainants allege that the Respondents violated Article IX, Section A, of the Erie County Human Relations Commission Ordinance No. 59, 2004 (as amended by Ordinance No. 39, 2007).<br />The allegations in the foregoing paragraphs hereof constitute an unlawful discriminatory practice and are in violation of the Erie County Human Relations Commission Ordinance No. 59, 2004 (as amended by Ordinance No. 39, 2007).<br />The Complainants have filed an Appeal of the Respondentsโ denial of their zoning variance request with the Court of Common Pleas of Erie County, Pennsylvania, but no action based on the aforesaid allegations of discrimination has been instituted by the Complainants in any court or before any other commission within the Commonwealth of Pennsylvania.<br />The Complainants pray that the Respondents be required to provide all appropriate remedies under Article VI, Section L of the Erie County Human Relations Commission Ordinance No. 59, 2004 (as amended by Ordinance No. 39, 2007) and to provide such further relief as the Commission deems necessary and appropriate.<br />IN THE ERIE COUNTY HUMAN RELATIONS COMMISSION<br />ROBERT E. WIDING III, VICTORIA)<br />HOUSE COLLABORATIVE LLC, and)Docket No. 10-002-H<br />JOHN DOES ONE THROUGH FIVE)<br />(Other Current and Prospective)<br />Residents of 1156 West 11th Street),)<br />)<br />Complainants and Plaintiffs)<br />)<br />)<br />)<br />CITY OF ERIE ZONING HEARING )<br />BOARD; CITY OF ERIE, BUREAU OF )<br />CODE ENFORCEMENT; and CITY)<br />OF ERIE,)<br />)<br />Respondents and Defendants)<br />VERIFICATION<br />I hereby verify that the statements contained in this complaint are true and correct to the best of my knowledge, information and belief and that I am authorized to make this verification on behalf of all Complainants herein. I understand that false statements herein are made subject to the penalties of 18 PA C.S. Section 4904, relating to unsworn falsification to authorities.<br />________________________________________________________________<br />SignatureDate<br />________________________________________<br />Street Address<br />________________________________________(______)________________<br />City, State and ZIP CodeTelephone Number<br />IN THE ERIE COUNTY HUMAN RELATIONS COMMISSION<br />ROBERT E. WIDING III, VICTORIA)<br />HOUSE COLLABORATIVE LLC, and)Docket No. 10-002-H<br />JOHN DOES ONE THROUGH FIVE)<br />(Other Current and Prospective)<br />Residents of 1156 West 11th Street),)<br />)<br />Complainants and Plaintiffs)<br />)<br />v.)<br />)<br />CITY OF ERIE ZONING HEARING )<br />BOARD; CITY OF ERIE, BUREAU OF )<br />CODE ENFORCEMENT; and CITY)<br />OF ERIE,)<br />)<br />Respondents and Defendants)<br />CERTIFICATE OF SERVICE<br />I hereby certify that a true and correct copy of the within complaint was served on all parties of record in this proceeding in accordance with the requirements of 1 Pa. Code 33.31 (relating to service by an agency) by hand delivery to the Complainants; and, to each of the Respondents, by certified United States mail, return receipt requested, postage prepaid, as follows:<br />Robert E. Widing IIIVictoria House Collaborative LLC<br />1156 West 11th Street1156 West 11th Street<br />Erie, PA 16502Erie, PA 16502<br />John Does One Through FiveCity of Erie Zoning Hearing Board<br />1156 West 11th Street626 State Street<br />Erie, PA 16502Erie, PA 16501<br />City of Erie, Bureau of Code EnforcementCity of Erie<br />626 State Street626 State Street<br />Erie, PA 16501Erie, PA 16501<br />Dated this ____________ day of March , 2010.<br />BY: ___________________________________<br />THE COMMISSIONโS ROLE<br />The Erie County Human Relations Commission Executive Director, Joseph Aguglia, Jr., acts as the attorney for the Commission who investigates the claim. In no way is the Executive Director, any representative of the Commission, and/or the Commission itself your attorney or representative. In fact, you are encouraged to retain private counsel if possible. If you desire to have an attorney, please contact the Lawyer Referral Service of the Erie County Bar Association:<br />Erie County Bar Association<br />Lawyer Referral Service<br />302 West 9th Street<br />Erie, PA 16502-1427<br />Phone: (814) 459-4411<br />The Human Relations Commission, Commission Staff and the Executive Director do NOT give legal advice to you. Both the Commission and the Executive Director act as a neutral court in the matter.<br />________________________________________________________________<br />SignatureDate<br />________________________________________<br />Printed Name<br />________________________________________<br />Street Address<br />________________________________________( )________________<br />City, State and ZIP CodeTelephone Number<br />