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SOPKO, NUSSBAUM, INABNIT & KACZMAREK <br /> ATTORNEYS AT LAW <br /> 5TH FLOOR-PLAZA BUILDING <br /> RICHARD A.NUSSBAUM,II' 210 S.MICHIGAN STREET OF COUNSEL <br /> BRENT E. INABNIT'• SOUTH BEND, INDIANA 46601 THOMAS C.SOPKO <br /> MATTHEW R.KACZMAREK <br /> TELEPHONE(574) 234-3000 <br /> KEVIN E.WARREN <br /> JOSHUA A.VISSER FACSIMILE(574)234-4220 <br /> NICHOLAS J.DERDA E-MAIL ADDRESS:SNI®SNI-LAW.COM <br /> WILLIAM M.SIDERITS <br /> CHRISTINA M.SHAKOUR <br /> 'ALSO ADMITTED IN MICHIGAN MEMORANDUM <br /> "ALSO ADMITTED IN ILLINOIS <br /> TO: Honorable Members of the South Bend Common Council <br /> FROM: Richard A. Nussbaum, II, Attorney for Women's Care Center, Inc. ("WCC") <br /> RE: Petition of WCC to rezone 3527 Lincoln Way West("Property")from SF-1 to OB <br /> DATE: April 5, 2018 <br /> In anticipation of the public hearing on the WCC Petition,I wanted to provide some information in <br /> writing to assist you in your deliberations. The following format will be used to be as efficient as possible <br /> given the multiple issues you need to address at each Council meeting. <br /> Filed it C!arr!x':, (,; ;ce <br /> I. Introduction —----- ----. <br /> II. Zoning Criteria _ <br /> III. Addressing Concerns Raised by Remonstrators LAPR. 0 5 2010 1 <br /> IV. Conclusion <br /> I. INTRODUCTION <br /> The WCC has been in existence since 1984. It is now in ten (10) States and twenty-nine (29) <br /> locations providing services to women prior to the birth of their babies, and most importantly, after the <br /> child is born. WCC helps the moms of two (2) out of three (3) babies born in South Bend (see folder <br /> attached) and this mission provides tremendous value to our community. In fact, if you quantify tangible <br /> items like diapers,cribs,vitamins,(new)baby clothing,baby books,pregnancy tests and ultrasounds given <br /> away without any charge to young women, it amounts to Six Hundred Thirty-three Thousand and 00/100 <br /> Dollars($633,000.00)each year in St.Joseph County alone. And this does not even include the thousands <br /> of hours of parenting,healthy pregnancy and self-sufficiency education provided. Many of you have visited <br /> the WCC facility and we thank you for doing so. <br /> A gaping long time need for a location of sufficient size and quality on the west side (46619 and <br /> 46628 area codes)to serve women in their own neighborhoods is met by the property to be rezoned. The <br /> east side of South Bend and St Joseph County is well served by facilities of sufficient size and quality. <br /> When this opportunity to purchase the Property presented itself, WCC jumped at the chance. <br /> WCC is a tax-exempt corporation and relies almost exclusively on the generosity of benefaction <br /> and many volunteers. The services and items it provides clients are totally free of charge. It does not <br /> engage in any political lobbying or protesting whatsoever. Its mission is totally woman centric. NONE <br /> OF THE EMAILS THE COUNCIL HAS RECEIVED IN OPPOSITION TO THE WHOLE WOMAN'S <br /> HEALTH ALLIANCE FACILITY WAS AUTHORIZED BY OR SENT BY WCC. <br /> Page 1 of 4 <br />