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MCSWEENEY APPEAL BRIEF submitted 62522
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MCSWEENEY APPEAL BRIEF submitted 62522
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7/7/2022 3:23:03 PM
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exists and stay in our home, keeping in mind the important issues of neighborhood and historical <br />residential preservation. <br />We wish to resolve this matter amicably and with the blessing of the HPC and the Commission <br />and avoid the intervention of the Court and the time, trouble and expense of such intervention. <br />WHEREFORE, for the reasons set forth above, Petitioner prays the Common Council to <br />OVERRULE the HPC's unfounded, arbitrary and capricious denial of our application for a <br />Certificate of Appropriateness and immediately approve the plan of remediation, repair, <br />replacement and restoration proposed. <br />Respectfully, <br />Joyelle McSweeney <br />APPENDIX: LIST OF EXHIBITS <br />EXHIBIT A: Appeal Application <br />EXHIBIT B: Appeal Narrative <br />EXHIBIT C: Standards and Guidelines of the Chapin Park Historic District <br />EXHIBIT D: Attestation to deteriorated condition of windows by Greentree, Inc <br />EXHIBIT E: Correspondence with HPC liaison Adam Toering, suggesting revision to bid <br />EXHIBIT F: Othello's Elevated Lead Screening, 10/7/22 <br />EXHIBIT G: CDC Press Release Lowering Blood Lead Reference in Children <br />to 3.5 ugl/DL <br />EXHIBIT H: Full County Lead Investigation Report <br />EXHIBIT I: Excerpts of County Lead Investigation Report pertaining to windows <br />EXHIBIT J: Rejected Bid from House Doctor Innovation to replace every window (33 total) <br />EXHIBIT K: Initial bid from Greentree proposing 6 vinyl window replacement <br />EXHIBIT L: Initial Certificate of Appropriateness (COA) Application <br />EXHIBIT M: Revised Bid from Greentree, proposing 6 "wood -clad" aluminum window <br />replacements <br />EXHIBIT N: Denial of COA by HPC <br />
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