The local bishop is ahead of his skis on his demand for local approval to destroy the mission grounds. POPE FRANCIS DOES NOT SUPPORT the "Development" of Our Historic 1565 Shrine of Our Lady of La Leche/Mission Nombre de Dios Grounds in St. Augustine, Florida -- Comprehensive Plan Amendment No. 2018-0170 & Rezoning No. 2018-0171.
Thus, I have moved to DISMISS his application to destroy with "development" the grounds of Our Lady of La Leche/Mission Nombre de Dios.
PZB must reject the application as lacking any indicia of authority.
Here's what I filed with the City of St. Augustine a few minutes ago, with City's response to my records request:
-----Original Message-----
From: Ed Slavin
To: dgalambos
Cc: eaverysmith
Sent: Mon, Apr 29, 2019 12:58 pm
Subject: MOTION TO Deny/Dismiss Application, ORDER Cross-Examination: re: "Development" of St. Augustine's Shrine of Our Lady of La Leche/Mission Nombre de Dios Grounds in St. Augustine, Florida, -- Comprehensive Plan Amendment No. 2018-0170 & Rezoning No. 2018-0171
Dear Chairman Misterly, Vice Chair Zander, et al.:
1. Pope Francis has not endorsed this project, which would destroy our precious Our Lady of La Leche/Mission Nombre de Dios mission grounds with a 800 seat amphitheater and three-story parking garage.
1. Pope Francis has not endorsed this project, which would destroy our precious Our Lady of La Leche/Mission Nombre de Dios mission grounds with a 800 seat amphitheater and three-story parking garage.
2. There is no evidence in the record establishing any authorization from the Pope, the Vatican and the Holy See.
3. The local bishop's application is thus ultra vires under Florida and local land use planning law.
4. It is an affront to local Roman Catholics. It may also be a violation of canon law, violating the principles enshrined in Pope Francis' May 24, 2015 encyclical on the environment, Laudato Si. https://w2.vatican.va/content/dam/francesco/pdf/encyclicals/documents/papa-francesco_20150524_enciclica-laudato-si_en.pdf
5. Please DENY the application for lack of any proof of any authority from Pope Francis and the Vatican.
6. Please GRANT me time to cross-examine any applicant witnesses in any further hearings, and to call them as adverse witnesses whether or not called by the applicant's counsel, by analogy to F.S. 90.612(3), sentence 3, allowing leading questions of witnesses identified with an adverse party.
7. Please place this e-mail chain in the record of City of St. Augustine Comprehensive Plan Amendment No. 2018-0170 & Rezoning No. 2018-0171. See below.
Thank you.
With kindest regards, I am,
Sincerely yours,
Ed Slavin
904-377-4998
www.cleanupcityofstaugustine.blogspot.com
www.edslavin.com
-----Original Message-----
From: Ed Slavin
To: recordsrequest
Sent: Mon, Apr 29, 2019 12:43 pm
Subject: Re: Request No. 2019-166: Ugly "Development" Proposal Threatening Our Historic 1565 Shrine of Our Lady of La Leche/Mission Nombre de Dios Grounds in St. Augustine, Florida -- Comprehensive Plan Amendment No. 2018-0170 & Rezoning No. 2018-0171
Thank you. Filing motions shortly.
With kindest regards, I am,
Sincerely yours,
Ed Slavin
904-377-4998
www.cleanupcityofstaugustine.blogspot.com
www.edslavin.com
-----Original Message-----
From: St. Augustine Public Records
To: Ed Slavin
Sent: Mon, Apr 29, 2019 11:15 am
Subject: RE: Request No. 2019-166: Ugly "Development" Proposal Threatening Our Historic 1565 Shrine of Our Lady of La Leche/Mission Nombre de Dios Grounds in St. Augustine, Florida -- Comprehensive Plan Amendment No. 2018-0170 & Rezoning No. 2018-0171
From: St. Augustine Public Records
To: Ed Slavin
Sent: Mon, Apr 29, 2019 11:15 am
Subject: RE: Request No. 2019-166: Ugly "Development" Proposal Threatening Our Historic 1565 Shrine of Our Lady of La Leche/Mission Nombre de Dios Grounds in St. Augustine, Florida -- Comprehensive Plan Amendment No. 2018-0170 & Rezoning No. 2018-0171
The City of St. Augustine does not possess any documents responsive to your public record request.
-----Original Message-----
From: Ed Slavin
To: dgalambos
Cc: tupchurch
Sent: Thu, Apr 25, 2019 3:19 pm
Subject: Re: Request No. 2019-166: Ugly "Development" Proposal Threatening Our Historic 1565 Shrine of Our Lady of La Leche/Mission Nombre de Dios Grounds in St. Augustine, Florida -- Comprehensive Plan Amendment No. 2018-0170 & Rezoning No. 2018-0171
Dear Mayor Upchurch, Ms. Galambos, Ms. Lopez, Ms. Skinner and Messrs. Cary, Birchim and Regan, et al.:
1. Please send me any document ever provided by the applicant local bishop evidencing any written authorization ever given by Pope Francis for the "development" of our sacred, historic Shrine of Our Lady of La Leche/Mission Nombre de Dios grounds with a three-story parking garage and a 800-seat amphitheater, on the site of Pedro Menendez's September 8, 1565 landing and founding of St. Augustine, Our Nation's Oldest City.
1. Please send me any document ever provided by the applicant local bishop evidencing any written authorization ever given by Pope Francis for the "development" of our sacred, historic Shrine of Our Lady of La Leche/Mission Nombre de Dios grounds with a three-story parking garage and a 800-seat amphitheater, on the site of Pedro Menendez's September 8, 1565 landing and founding of St. Augustine, Our Nation's Oldest City.
2. Please send me any document(s) ever provided by the applicant containing any legal analysis of canon law regarding the implications of the bishop's apparently ultra vires "development" proposal possibly violating the principles enshrined in Pope Francis' May 24, 2015 encyclical on the environment, Laudato Si. https://w2.vatican.va/content/dam/francesco/pdf/encyclicals/documents/papa-francesco_20150524_enciclica-laudato-si_en.pdf
3. Please send me any City staff legal analysis of steps to issue letters rogatory from the City of St. Augustine to the Holy See in the Vatican concerning Pope Francis' position on the "development" of our Shrine of Our Lady of La Leche/Mission Nombre de Dios grounds with a three-story parking garage and 800 seat amphitheater. If none exists, please provide one, on an urgent basis as the public interest requires it.
4. I have sent a copy of this e-mail to our Papal Nuncio (Vatican Ambassador) in Washington, D.C., to Fr. Thomas Willis at our St. Augustine Cathedral Basilica, to our bishop's staff, et al.
5. The owner of the land in quo is the Roman Catholic Church, headed by Pope Francis since his election on March 13, 2013.
6. The owner is not one "Charles J. David," who is erroneously listed as the "owner" in documents filed by the Rogers Towers corporate law firm and City. Please correct our City records accordingly.7. Please make this e-mail -- and any responsive documents to it -- a part of our public hearing record in re: City of St. Augustine Comprehensive Plan Amendment No. 2018-170 and Rezoning No. 2018-171:
Comprehensive Plan Amendment
2018-0170 Ellen Avery-Smith – Applicant
C/o Rogers Towers
Charles J. David – Owner (sic)
C/o Bishop of the Diocese St. Augustine, Bishop of the Diocese Catholic Center & Roman Catholic Church
PIN #’s: 1920900000, 1920700000, 1959600000,1959300000, 1959200000, 1958500000,1920800000, 1908800000, 1909000000,1909100000, & 1908900000 (Area roughly bounded by Ocean Ave., points immediately north of Ocean Ave. near the Matanzas River, Matanzas River, Pine Street, & San Marco Avenue.)
To amend Future Land Use Map designations from Public/Semi-Public, Open Land and Residential Low Density to Commercial Low Intensity.
Rezoning
2018-0171 Ellen Avery-Smith – Applicant
C/o Rogers Towers
Charles J. David – Owner (sic)
C/o Bishop of the Diocese St. Augustine, Bishop of the Diocese Catholic Center & Roman Catholic Church
PIN #’s: 1920900000, 1920700000, 1959600000,1959300000, 1959200000, 1958500000,1920800000, 1908800000, 1909000000,1909100000, & 1908900000 (Area roughly bounded by Ocean Ave., points immediately north of Ocean Ave. near the Matanzas River, Matanzas River, Pine Street, & San Marco Avenue.)
To approve a rezoning from Open Land (OL) and Residential Single Family 2 (RS-2) to Commercial Low-Two (CL-2).
With kindest regards, I am,
Sincerely yours,
Ed Slavin
904-377-4998
www.cleanupcityofstaugustine.blogspot.com
www.edslavin.com
-----Original Message-----
From: Ed Slavin
To: dgalambos
Cc: tupchurch
Sent: Thu, Apr 25, 2019 1:25 pm
Subject: Request No. 2019-165: March 13, 2019 letter to Mayor Tracy Upchurch from Roman Catholic Church counsel re: proposed mission grounds development
Dear Ms. Galambos:
Please send me the March 13, 2019 letter to Mayor Tracy Upchurch from Roman Catholic Church counsel re: mission grounds development, together with any staff or public responses and analysis.Thank you.
With kindest regards, I am,
Sincerely yours,
Ed Slavin
904-377-4998
www.cleanupcityofstaugustine.blogspot.com
www.edslavin.com
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