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Honorable Members of the City Council <br />January 18, 2000 <br />Page 2 <br />4. The decision of the Planning Commission denies the applicant his constitutional <br />right to use his property and to develop his property. <br />5. The decision of the Planning Commission together with prior decisions of the <br />Planning Commission and the City Council do not permit applicant to develop his property in <br />any meaningful way. <br />6. The decision of the Planning Commission constitutes a taking of the applicant's <br />property without just compensation. <br />7. The decision of the Planning Commission constitutes an inverse condemnation of <br />applicant's property. <br />For these reasons, applicant seeks to appeal to this Honorable Council to reverse the <br />decision of the Planning commission and to grant the application. <br />SMB/mc <br />X:\FELES\M021\MO21.08\APPEAL.L01 <br />Sincerely, <br />Attorney for Applicant <br />Jq <br />