DARLENE & MERT KING FAMILY LTD. PARTNERSHIP, LLLP lo Regel & Associates 655 8. Sunset Street A ‘Longmont, CO 80501 ‘August 3,2015 RECEIVED By Hand Delivery: Gay Cle AUG 0 4 205 Gity of Longmont = Civic Center Administration Office GMON' CITY CLERK 350 Kimbark St Longmont, CO 80501 Re: _ Notice Of Appeal ~ Notices of Violation dated 7/28/2015 Department of Publie Works & Natural Resources Dear City Clerk: Pursuant to Municipal Code §13.24.170, we appeal the Notices Of Violation, dated July 28, 2015, isued by the Drecor of Public Works and Natural Resouces. Notices were sent to Edward C.Regel; Kathy L Regl and Jacque Wagner. The Notices concern the removal of tees 8750 W. 9 Avenue in Lingmont Issues important to our appeal include: 1. Ownership. The documents we have, show that the property underlying the toes is ‘owned by the King Family Partnership, not the City. At least one city official told us the planter boxes are on KFP property. We acted in good faith in the belief that the KFP is the owner ofthe tres and the ground under the trees. Maintenance records and history will be important to this issue. 2. Amount of damages. Given our good faith belief that we owned the trees, we don’t think there should be any assessment of damages, even ifthe City records show it owned the trees. At the least, given the condition and age of the trees and the liability risks they presented, we think the damages are excessive. 3, Who is liable, If thor is libilty for damages, only the record owner should be 4. We may have other issues as we leam more liable We will be represented by our attomey, Richard Marsh with Pipis March Law LLP, 255 ‘Weaver Park Road #200, Longmont, CO 80501, Tel: (303)-776-8499. Questions concerning this ‘matter may be sent to him. Respectfully submited, Darlene & Mert King Family Ltd i: Partnership, LLLP py Lent Ib bee Regal & Associates, LLC