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HomeMy WebLinkAboutZaino, Louis - Denied WHEREAS, a petition was heretofore flied with the Town Board of the Town of Southold by .~.°.~.~,~...-~.~.~.n.-.°...~-..~.~....A-.~'.~-.z3~-.°....~-9~'.~'9'~:~'~-' ....... requesting a change, modification and amendment of the Building Zone Ordinance including the Building Zone Maps made a part thereof by chang- A Reszdentzal & · . "B-l" General Business lng from ................. , ...... , ........... , ....... D~stnct to ............................................ Agr zcuituraz District the property described in said petition, and WHEREAS said petition was duly referred to the Planning Board for its investigation, recommendation and report, and its report having been flied with the Town Board, and thereafter, a public hearing in relation to said petition having been duly held by the Town Board on the .....2..7.~.~ ...... day of ................. .~.~..c~:~.~ ................ , 19~.~_..., and due deliberation having been had thereon NOW, THEREFORE, BE IT RESOLVED that the relief demanded in said petition be, and it hereby is DE~TED. BY ORDER OF THE SOUTHOLD TOWN BOARD DATED: September 24, 1974. ~lbert W. Ricl~ond, Town Clerk LAW OFFICES IRVING I. MILLER 83E pEPPERIDGE ROAD P,O. BOX WESTBURY, NEW YORK 11590 October 25, 1974 Albert W. Richmond, Town Clerk Town of Southold Town Clerk's Office Southold, N.Y. 11971 RE: Louis Zaino and Armando Sardelli Property: S/S Main Road and W/S Indian Neck Lane Dear Sir: Based on the application on behalf of the above captioned, a hearing was held by the $outhold Town Board in the Office of the Supervisor, at 16 South Street, Greenport, N.Y., on August 27, 1974, during which time Albert M. Martocchia presided, in connection with proposal to amend the Building Zone Ordinance. The undersigned representing the interests of the above captioned, together with them, appeared at said hearing, and had presented an argument in favor of the proposal and also submitted a Memorandum on behalf of the petitioners. To date we have not been favored with written disposition and would appreciate your attention and advice. At the time that the written decision is made and a copy of same forwarded to the undersigned, would you also please forward copies of the dispositions made by the respective Boards and Authorities who previously reviewed the matter. Thank you for your courtesy and cooperation. ery~ tru x, yours, i'~VING I. MILLER II~ '/rr Public Hea~ iX - Southold Town Board - ~ust 27, 1974 A public hearing was held at 8:00 p.m. August 27, 1974 in the matter of an application for a change of zone presented by Zaino and Sardelli. Present were Supervisor Albert Martocchia, Councilman James H. Rich, Jr., Councilman James F. Homart, Justice Martin Surer and Justice Louis Demarest. Councilman Rich read the Notice of Hearing. Pursuant to Section 265 of the Town Law and Requirements of the Building Zone Ordinance of the Town of Southold, Su££olk County, New York, public hearing will be held by the Southold Town Board in the Office of the Supervisor, 16 South Street, Greenport, New York, in said Town, on the 27th day of August, 1974, on the following proposal to amend the Building Zone Ordinance (including the Building Zone Maps) of the Town of Southold, Su££olk County, New York. 8:00 p.m. (E.D.S.T.) by changing from "A" Residential and Agricultural Distr±ct to "B-I" General Business District the property of Louis Zaino and Armando Sardelli situated at Peconic, Town of Southold, Su££olk County, New York, and more particularly bounded and described as follows: BEGINNING at the corner formed by the intersection of the southerly side of Main Road (Route 25) and the westerly side of Indian Neck Lane; thence south 24° 00' 00" East along the westerly side of Indian Neck Lane a distance of 212.05 feet to a point located on the northeast corner of the land now of Louis Zaino and Armando Sardelli; thence running in a southwesterly direction along a southerly line of the land now of Louis Zaino and Armando Sardelli South 46° 35' 20" West 530.41 feet to a point; thence running in a northerly direction along the easterly line of the land now or formerly of Rose Koraleski North 21° 47' 10" West 215.14 feet to a point located on the southerly side of Main Road (Route 25); thence running in a northeasterly direction along the southerly side of Main Road (Route 25) North 460 35' 20" East 521.59 feet to the concrete monument, the point or place of BEGINNING. Any person desiring to be heard on the above proposed amendment should appear at the time and place so specified. Dated: August 12, 1974 BY ORDER OF THE SOUTHOLD TOWN BOARD ALBERT W. RICHMON, TOWN CLERX Proof of publication was presented. The following letter under date of August 5, 1974 was presented from the Suffolk County Department of Planning. Dear Mr. Richmond: Public Hea~ .g -2- ~gust 27, 1974 Pursuant to the requirements of Sections 1323 to 1332 of the Suffolk County Charter, the Suffolk County Planning Commission has reviewed the above captioned zoning action and has disapproved this ohange of zone because of the follow- ing: 1. It is inconsistent with the Town Master Plan which designates this area for residential development; 2. It is inconsistent with the pattern of zoning in the locale and therefore must be considered as "spot zoning"; 3. It would tend to establish a precedent for the further perpetuation of undesired strip commercial develop- ment along Rte. 25; and 4. It is inconsistent with the residential character of the surrounding area. /s/ Gerald G. Newman Chief Planner The following letter under date of July 10, 1974 was received from the Southold Town Planning Board. Gentlemen: The following action was taken at a regular meeting of the Southold Town Planning Board held on July 8, 1974. On motion made by Mr. Wickham, seconded by Mr. Raynor, it was RESOLVED that the Southold Town Planning Board recommend to the Southold Town Board denial of the petition of Louis Zaino aud Armando Sardelli requesting a change of zone on certain property situated at Peconic, New York, from "A" Residential and Agricultural District to "B-l" General Business District. This petition seems to be based on the illegality of the zoning law. To the best of the knowledge and belief of the Southold Town Planning Board the zoning laws of the Town of Southold are constitutional and were adopted after due process and the Southold Town Planning Board feels that the existing use of the property as zoned is correct. Vote of the Board: Ayes: Wickham, Raynor, Coyle, Moisa. Absent: Grebe. /s/ Muriel Brush, Secretary Proof of posting by the Town Clerk was presented. Supervisor: You have heard the legal notice read, the description of the property, the legal advertising in the proper papers - the official papers of the Town of Southold, the posting by the Town Clerk, the position of the Town Public Hea~ g -3- ~gust 27, 1974 Planning Board recommending denial, the position of the Suffolk County Planning Board recommending denial. At this time, I will entertain anyone who wishes to speak for the applicant. Irving Miller: My name if Irving Miller and I am the attorney for the petitioner. With the Board's permission, I would like to speak on their behalf and acquaint the Board, first of all, with some background history concerning this parti- cular property at the request of my clients. Mr. Miller presented Schedule "A" distributed to the Board and attached hereto. Supervisor: Does anyone else wish to speak in favor of granting this change of zone? Anyone wish to speak in opposition? Loraine S. Terry, North Fork Environmental Council, Inc.: In regard to the application of Louis Zaino and Armando Sardelli for a change of zone from A to B-l, location: Indian Neck Lane and Main Road, Peconic, New York, the North Fork Environmental Council strongly opposes the granting of this change for the following reasons: (1) The Master Plan shows this property to be A-R and we feel this plan must be followed for orderly growth in Southold Town. (2) We feel the granting of this would be "spot zoning" and change the character of the area, one we feel is one of the finest agricultural residential areas in Southold Town. (3) Again we feel that a change of zone without restrictions could produce numbers of problems as there is no guarantee as to the business that would be placed there if the owner's plans change or that the property changes hands. We do therefore urge you to deny this application. And may I make one comment. Comments about newspapers. I own property in Maine and I feel it is up to me to find out what happens to that property by subscribing to a newspaper in that area so I will know what is happening. I feel this generally has to be done by people. It is your responsibility to take care of your possessions. No one else is doing it for you. I think the newspaper's circulation is demeaned by Mr. Miller's remarks. I think we have a fine newspaper that keep us all informed. It is up to property owners to subscribe to that paper or one designated by the Town. Supervisor: Anyone else wish to speak in opposition. William Blake: I live on Indian Neck Lane in Peconic. I would like to second what the lady just said. I live in Nassau. I subscribe to both the Suffolk Times and the Traveler for just the reasons she cites. I think Mr. Miller is quite wrong on that. I have alot of friends who own property out here, some that live in Florida, some that live in Arizona and I think it would be hardly possible for the Town Board to advertise in all the papers that all the people all over the country could possibly see. I think, as the lady said, it is up to the property owner to have Public Hea~ ~g -4- ~gust 27, 1974 enough interest in their property to subscribe to a paper in the local area where they own the property. I would like to say that the letter the gentleman read from the Suffolk County Board expresses my views exactly. I think that was a very well written letter and the reason they turned it down and I concur with it wholeheartedly. Jean Tiedke: It occurs to me that perhaps the original change from A-R to B-1 was an injudicious decision by the then Town Board and that was indeed "spot zoning" and the change in the Master Plan back to A-R was rectification of that. I would like to ask Mr. Miller or anyone else who can answer to cite me chapter and verse in the constitution where it guarantees a favorable return on an investment. I would like to know about that. Mr. Miller: There is nothing per se that says in any constitution whether it is the Federal or the State constitu- tion they will guarantee a fair return but it does specifi- cally say that those of us who are real property owners are entitled to make the best use of this property without being deprived of its use by any town or municipality or other person or otherwise in the event that it is being done contrary to the constitutional provisions of ownership of real estate. I am not saying, in fact, that the Town Board does not have that authority or power. As a matter of fact, in my memorandum that I read and that I submitted before the Board I acknowledged that the Town Board does have that authority and is vested fully with it. I am not challenging that aspect of its constitutionality. I am challenging the fact that there was not proper notice given to those who are property owners here but do not reside in this community so they would not be aware of what was going on. You have to also take into retrospect a certain situation. The fact is that Mr. Zaino and Mr. Sardelli did not become the record owners of this property until sometime in June of 1970. This enactment or at least the prefacing situation which followed by the enactment became manifest and became involved and became constitutionally enacted sometime in September of 1971. While it is a year or a little bit more than a year that transpired, it is certainly true that the record owners did not have the opportunity necessarily to become acquainted with what was going on locally. I say this, that this Board has an obligation to all record property ovn~ers who are tax- payers, who receive tax bills in the mail, to be informed by mail if they are out of town residents, perhaps even to the extent of those that are residents here, to receive notices in the mail directly from the official source instead of being dependent on a newspaper article, notwithstanding that the Suffolk Times is the quasi-official paper or is the official paper of the Town of Southold. I did not mean to demean the newspaper per se. I think it happens to be a pretty good newspaper. I am aware fully that on one or two occasions it has won awards for its journalism. Off the record, I would be the least one to criticize the newspapers because at one time I aspired to be a journalist. I am surely not taking the Suffolk Times to task here. I am Public Heat .~g -5- .ugust 27, 1974 saying that the opportunity of the petitioners was not there for them to ascertain through the newspaper the notice of the intended change. This deprived them of the fact of coming in and making their opposition locally or by voice and this, in fact, deprived them of doing anything that they may have wanted to do prior to this occasion to take the necessary steps to protect their real property rights. Stuart Moran, President of the Indian Neck Park Association: I have heard tonight and never before have I heard such a manifestation of ambiguity. After listening to the attorney present his position, intellectually I cannot say I know what the hell he is saying. What he is asking for, whose rights he is speaking for. One thing I found very effective. He alludes to constitutional rights, the constitution. We all know who play with law that you must go to the Supreme Court when you are speaking constitution and you must be an expert in it. I have heard the Town Board insulted, the local newspapers insulted. I am not taking a position on either part. My biases are my own. One thing I can't live with, I don't think any intelligent man can live with, and that is a presentation fifteen or sixteen pages that says in essence to me nothing on one premise. It does not say what they are asking for. The position of my association is this, that the variance has ambiguity. The variance con- stitutes without question a dew, zoning. A do~rnzoning in any form is a cancer in this community. If we give one aspect of it we must commit ourselves to another. Thank you. James Knowles: I have brought with me a petition signed by sixty-eight residents of Indian Neck Road and environment. I submit this for the record. These are all opposed. May I paint out to Mr. Miller if he will investigate the use of this farmland immediately behind he will find that Farmer Mike has been farming that for over three years and I doubt that Mr. Cichanowicz had anything to do with it. Supervisor: Does anyone else wish to speak in opposition? Ms. Tiedke: Does the old saw 'Let the buyer beware' still hold? Supervisor: I think it behooves the attorney representing a client that he do all the researching. And what the lady said about 'Let the buyer beware', I learned that a long time ago the hard way and you remember when you learn it the hard way and I agree with the attorney. In my opinion, he perhaps did not guide his client too well in touching all the bases before he let his client buy the land, thinking he was buying under one category and it was not, because of changes taking place from time to time. I am sure the Town of Southold or any town in this United States or village can advertise all over the world to cover taxpayers that own property that live in many areas. It would be quite a task to go to every section of this world to reach property owners in any given town. We not only advertise in one official paper and it staggers each year but it is covered by both papers, the Public Hea~ ~g -7- gust 27, 1974 of the community. Supervisor: Does anyone else wish to comment on this appli- cation? Mr. Moran: Just a question, sir. This is absolutely open. Would the town reclassify a zoning, is this a precedent what the gentleman is speaking about tonight? Supervisor: When we revised our zoning a couple of years went into it. There were many hours of study before we adopted one piece of it. There were many hours until two o'clock in the morning pouring over the maps and with guidance from all our agencies and county agencies there was indication at that time that any pieces or small strips along the Main Roadways if they were not in use were considered discontinued. Supervisor: Anyone else? Has everyone had an opportunity to be heard? Thank you for coming. The hearing is closed. A determination will be made. Hearing closed at 9:10 p.m. Respectfully submitted, Muriel Brush, Secretary ~n ~he ~atter 0£ The ~IS ZAZNO and AR~NDO SARI~LLZ 0 Petitioners, For A Change, Modification Or Amendment O~ The Build£ng Zone Ordinance Of The Town of Southold, Suffolk County, New York. FACTUAL ]aaC]~RO~JND HZSTORY ~ne Petitioners herein on April 25, 1970, entered into a Contract of Sale as Purchasers between themselves one ALbeRT A. ~ACCO, residing at Hill l~c~d, To~n of Suffol~ C~nty, as Seller, which enc~sse~ an~ includea the b~nde~ Ln Pa~graph "1' o~ the ~t~tion and more ~rticularly ~ ~tion thereof ~ich is the s~j~t mtter ~ore ~s ~r~ as is l~ntified ~ ~ragra~ =2" of ~e Petition, ~].y e~ecuted ~e 5, 1974. The subject real property is further supplemented description by the m~ps c~ated ~ay 8, 1974 made by RODHRICK VAN TUYL, P.C., Greenport, New York, heretoffore submitted with the Petition. The Contract of Sale/Purchase contained a specific representation and warranty fro~ the Seller to t_~e P~'rchasers at Paragraph "7" of the Rider as follows: "7. The seller hereby represents and warrants that the premises here/~ being demised, that portion thereof set on the Main Road for a distance of 521.49' to a depth of 200', are zoned "B# Business under the Southold Town Zoning Ordinance. The seller further represents and warrantu that as to the re~ining portion of the premises covered by this contract, said premises are zoned #A" Agricultural and Residen- tial under the Southold Town Zoning ordinance." Attached hereto and made a part hereof is a copy of said Contract. As will ~e seen from the foregoing, that porti~ thereof included the land which was affected by the change of zoning resulting in ~he within application. A Deed completing the conveyance of the aforesaid transaction was given on J%me 19, 1970 and recorded at the Suffolk County Clerk's Office on J~ne 23, 1970, under Liber 6761, Page 41. At that time, the s~bject real property (fr~ntingMain ~ad) was "B" Business zoned and classified. It would appear, that thereafter The Suffolk T/mss newspaper, on or about in its September 15, 1971 edition, did publish a Notice of Hearing to have been held by the Pace ~ - Board of the T~wn of Southold on September 28, 1971 in the matter of the amendment of the T~wn Ordinance entitled "The Building Zone Ordinance of the T~n of Southold, Suffolk C~unt¥0 New York". The Ordinance was enacted on November 23, 1971. At that time both Petitione~s were residents of the C~ant¥ of Nassau. The property in question had upon it at least oae building. This building, upon information and belief, had been used by Briarcliff Sod, Inc., in connection with its business, who tenanted the real property for purposes of sod growing and development prior to the time that the Petitioners became o~ners of said property and up to and including October 15, 1970. Some time thereafter, in and about March of 1972, Petitioners e~tered into a lease arrangement for a term of one year with one ROBERT ADIPIETRO, trading as The Old Trad~lg Post Antiques for the use and occupancy of the aforementioned building premises located as aforesaid. This lessee proceeded to possess a~d occupy the premises and improve same for the retail establim%hment intended. He then applied to the Building De~mrtment for a sign permit, which was denied him on the basis that the property had b~un re-zoned contrary to its - Psg~ 3 - previous classification, to wit, for "Business"use. The lease arrangements b~tween the Petitioners and ~aid tenant were thereupon caused to be termizlated at a substantial loss and detriment to the Petitioners. Thtzs, for the first time ever, did Petitioners, and about May, 1972, learn of the re-zoning of the real pro~rty owned by them. POINT X~ NOTXCE IS A PKB~XSXT~ TO COMPIJANCE OF STATUTORY AUTHORITY The grant of statutory power given to the Town of Southold to enact laws respecting use of property is not in and of itself being challenged by Petitioners. It is taken that. a tc~n zoning board may exercise its power to make zo~in%- re?ulations only to p~omote haalth, safety, morals or ~en~rsl welfare of the com~anity. ~wever, such statutory power to enact laws respecting use of property is subject only to constitutional limitations that it not be e~erted arbitrarily and tlnreasonably, and also that it must with the proce~aral prerequisite statutes. Section 264 of the Town l~aw outlines the required - Page 4 - procedural steps by a Town Board in enacting an ordinance or amendment thereto. 'The town board shall provide for the manner which such regulations and restrictions and the boundaries of such districts s~all be determined, established and enforced, and from time to time amended, supplemented o~ changed. However, no st~h regulation, restrictions or boundary shall become effective until after a D~tblic heerinq in relation thereto, at which Parties in interest and citizens shall have an o~Dortttnit¥ to be (under scori,g mir,) The same section further provides that "At least ten days~ notice of the ti~e and place of such hearing shall be published in s ~a~er of qe~eral circulation in such town. (underscoring mine) In retrospect, we find as a ~atter of that The ~uffolk Times, the ~ecLared official newspaper of Southold Town. was a we~kly tabloid, published every Friday, additionally distributed in the main (and perhaps nowhere else) in the Village of Greenport an~ ~erving Shelter Isla~ (b) by its own "mast-head" o~ Page 6 of the September 16, 1971 issue, it refers to itself as #a we~kly journal for the country fireside# devoting itself to 'literature, intel~igenoe and lo~a~ affairs"~ (c) that the Petitioners, ~ere both residents of Nassau County (at We~tbu~y, New York) without ~ny linkage to the To~n of Southold, el~er by -Page bueinees~ personal, friend o~ family, e~cept for the Eecord wit, ~ne Suffolk Times, is not sold or ~en~rallv distributed in l~saau County. It ~an hardly be held, notwithstanding its (The Suffolk Times) quasi official design~tion, that this is a "paper of general circ'alation". Ln this ~y and age, pr~tri- etary t/lterest is not limited to the confines o£ your own p~rcel upon which you make your home, but on the contrary~ property ownership is spread far and wide throughout the co~ultry and world e~clusive of yo%lr ~omiciliary or the piece where yo~ hang your hat. O~ the basis of such acknowledged premise, the n~lco which is mandeted by the statute, restricted to the local ptlbli~ation, f&lls short of the required public~tio~ of ~otice re. movably required to apprise the public of the esser~e of the reg~lations to be adopted. See, PALIOTTO v. TO~N OF 1962, 31 Misco2~, 447~ 224 b~2~ 466 (reversed cai other grounds) thlder the circumstances, it is respectf~ally that nothing s~ort of person~i or mail service of the Notice than s~ch effectiveness against -Page 6- Petiti~ners' Land, the Notice was inadequate, precludL~g Petitioners fr~n exercising their ri_~ht to oppose, and any subsequent actions taken bases on thnt Notice are likewise inv~ lid. That the ~nited States ~alareme Court is disposed to expanding such doctrine or ~t~,a, is evident fr~m its re~ent deeisl(Ma, ~ v. ~, 92 S.Ct. 1~3 (~972), where C~ st~=k ~ a ze91evin s~tute whi~ ~itted the ~r~tr~l ~e of ~attel~ %;ithout notice to ~e N~g ~mt pro~rty rights are no les, sacred than ri~ts, ~e C~rt held ~t "'the constitutio~l right heard is a ~ic aspect of the duty ~f g~r~ent to ~rs~ ~f his ~ssessions." 92 S. Ct. at 19~. It must significantly follow that if the right notice and a hearing is to ~erve its full is crystal clear that it must be granted in an %u%limited non-~eferre~ manner. The instant property aS far as ia kr~m, -~ 7- to the enmc%ment in November, 1971, had been ~ am an~ a business use and c~ssi~i~tion ~ince ~e original ord, i~ ~d in 1957. It hau ~c~,~ained u~devuloped ~ese ~ny years except as culti~ted for sod growin~ ~nd relate~ The 1972 Southold To~,n Zonin~ Ordinance, was inte~e~ to serve the public ~or the better:~ent of its health, snfety and welfare. Within this framework ~.ere is a pres%~,ption of ccu~scitutionalit~v applicable ol such 0rdin~ncc. not j~stified ~s it aff~ct~ the suDject property before this i~o~r~ in t~ it did not serve the ptlblic health, saf~-ty and w~Ifare anf~, ~ore particularly and sign_~ficant!l~, caused a~ economic injury and se~,~¢re finuncia! !os~ to the Petiti~rs. the ~3%TTER OF FULLING vs. PAI~O (Ct. App. ~,!¥ 1967) 21 NY2d 30, 286 ~$2d 249, 233, ~.E.2d 272, the C~rt s~id that the basic r%~le is "where the property owner ~i!l significant economic injury by the application of stan~rd ordi~nce, ~at stan~r~ can be justifie(~ only z~g that the ~blic h~ltk, ~fety '~.~ welfar~ will ~e -Page 8- Out of almost thirteen acres then owned by Petiti~n- ers, the Board through the Enactment reclassified 2.4L5 acres the extended width of which fronts on Main Road, so as to reduce it fram its business class to a "residential-agricult- ursl" take and worth status. By this arbitrary change, this Board may well "judicial" notice o£ the marked devaluation o~ the value of the property. In the growth of the c~maunity at large and the ~diate vicinity at and about where the a~eage is loceted~ and the manner in which it is located and situate, tl~e area has in fact bec0~e business and commercial oriented the Land per se re~ains more adaptable for business use as o~sed to residential use. The existing present ~oning use is an invasion of Petitioners* legal and constitutional right to own and put the property to its highest and best use, which is for ge~erel business use. One cannot take issue with the action contemplated by the ~nac~ment in seeking to maintain an area for residen- tial purposes as being a pro, er one. However, where such change is arbitrary or unreasonable considering all of the -Page 9- existing circl/mStance$ relativ~ to the ~rea object intended by the Board to be involved, the is contrary tO the overall consideration of the adaptability for such residential or ~gricultural use as was impose~ upon this acreage. The e~istin~ ordil~nce~ as ~pplied to it, amOUnts to co~£~Cation. Examination of the record in the planning t~azd the enactment o~ the said Ordinance clearly indicates the confiscatory an~ arbitrary n~ture of the designation of the category assigned to the acreage which was re-zoned in that 90~ of the acreage in Southold Town vas dealgnated #A', Agricultl/ral - Residential. This process of singling o~t a amall p~rce! of land. namely the Petitio~ers' property of 2.415 acres, for a use classification totally different fr~m~ that of its then classification to the detriment of the o~ner of such property, is clearly violative not only of pro, er re-zoning, but in p~rticular of the rights of-~ro~erty ~er- ship an~ its applicable use thereof. Notwithsta~ding the fact that the parcels or acreage to the rear of the pro~erty in question, being of co~aon ownership and rear c~ntiguity, did ]~ear and continue to be -Page 10- classified for residential agricultural ~ur~ses, the pxop- erty in ~es~ion ~t thi~ a~!i~tion is e~t~.tled to s~tus, n~ly, what it was ~fore, ~rti~l~.r!y ~at fringe ~here%f is on a ~blic strut amd i~ of a and di~inct ~ture. ~ ~tneain the classifica%ion as ~s ~fore d~ in no way change the character of the h~ or a~ruely eff~t the h~l~, ~lfare and ~fety of ~e c~unity and therefore the B~rd's action affect~ s~id pro~rty shoul~ ~ a~ulled. See, ~ C~ v. ~0, Sup.Ct., Suff91k C~nty, ~7, ~o~m~r 5, I973, p. 2,. CI{~.~F, J., citing ~Z~ v. C~, 59 MiSC.2d t050, 1052. %~rou~h~ut these ma~y mon%hs, notwithstanding the recL~ssification and ~tatus established to ~estion, ~e Petf.~:ioners here~n h~ve in in an effort ~3~) ~7~ake use of th~_s !and within the ~ope of u~rly ~ca~se ~e pro~rty is not reasonably resi~ntial use, in vi~ of its ge~ra~lc l~at~n. an ordi~n~e ~s so far as to preclu~ p~rty f~r any pu~ f~r whi~ it is ~rea~bly ~e~ it is c~is~t~ry and ~st -~e 11- almost the same type of circumstance as is prevalent herehl, the Court held in that case, that the town board's determina- tion was unreasor~ble, arbitrary and capricious, and that the ordinance ~as unconstit%lttonal in its application. what has occurred here by reason of the Enactment is a declaration to prevent the natural growth of the in accordance with a #c~.prehensive plan". In GOLDEN v. PZANNING B(~RD OF RA~PO, 30 ~d 359. the Court said, "Zoning is a means by which a governmental bo~y can plan for the future -- it may not be used an a ~eans to deny the It therefore must follow that the zoning pm~er of a mtulici- pality ~/=t have a legit~mate ~urpose, as well as a reL~t~otl to the p~liee p~wer and the social, physical and c~nditions ~ot ~nly within the munici~lity but within the entire region. If e~ch ordin~nce clothes its txue in rectit~d~ to effectuate an altogether different the ordinance will not be ~held and is in fact invalid. Here the property was "is~lated", that its restriction t~ residential agric~lt~arml use is ~areas~nmble a~d in fact there was n~ beeis or grounds u~on which to impose a reclassification of such isolated parcel of property. 12- ~qlat is especially ~igni£1cant is the f&ct th&t b~cause of ~e 9rox~ity nn~ l~ti~n of ~e p~rty, f~nt~ on ~in R~d, ~hich i~ a ~jor hi~y a~ traffic ~e ~rceI (acreage) is not ~ui~ble for resi~ntial ~r~e~re, tt is ~dis~d ~at by ~e e~c~nt as this pretty there is the reduction in ~lue of ~e ~r~l so as to p~clude ~e u~ of ~e p~y for ~e to ~h it was unr~sonably (e~n~ically) ad.ted. a~ is confi~atory and unconsti~ti~l. (~S v. OF ~. ~, 307 ~ 493) such a~ion as heretofore in ~e ~t~e of re-z~ing has t~lly ~stroyed ~e ~lue o~ O~ p~rty and signifi~ntly depri~d the Petitio~rs of ~eir ~terests ~ere~. It is respectfully contained that the zoning clmssi- fication affixed to the within l~ro~erty amounted to a reverse "spot zoning", and an ~unlaw£ul "taking" of pzol~erty withotrt due process. At such disposition it violates the Constitu- tions of ~e United s~ates and o~ ~/%e State of ~w York. -Page 13- Respect fully sub~itted, IRVING Io MILLER, ~s~. Attorney ~or pe~itioners Office & P.OoAd~ress ~32 Pe~peridge P~osd P.O. BoX 529 %~e~ltI:~ry, !~'.Y. 11590 (516) 333-2930 CONSULT YOUR LAWYER BEFORE SIGNING THIS ~.~$TRUMENT--THIS INSTRUMENT SHOULD BE USED BY LAWYERS ONLY. THIS AGR~'I=MENT, made the 7~ day of April , nineteen hundred and seventy BETVSEEN ALBERT A. EACCO, residi~'~g at Hill Road, Box 721, Tog;n of $0uthold, Suffolk County, New York, hereinafter descr~ed as the seller, and LOUIS ZAINO, residing at 21 ~. Grand :2=feet, Westbury, New York, 11590 and ARMANDO SARDELLI, re.~iding at 50 Lafayette Avenue, I,'estbury, New York hereinafter described as the purchaser, %V/TNESSETH, thattheselleragreesto ~llandconvey, andthepurchaseragreestopurchase, allthatcerta~plot, piece ~rparce~f~and~thtbebui~dingsandimpr~vementsthere~nerected~situate~yingandbeing)~ieat ~econLc, town of southold, County of Suffolk, ~tate of New York, bounded and descri~ed as follows: BEGXNN~N~ at the corner formed by the intersection of the southerly ~ide of Hain Road (Route 25) and the westerly side of Indian Neck ~ane; '~-~ South 24" 0O' 00" East along the westerly side of Indian Neck Lane a distance of 841.32 feet to a point located on the northgast corner of the land now or formerly of Albert M. Garbade; '~CE R~I~ im a s~therly dir~tion along the northerly line of the land ~ or fo~erly of Alert M. Oarbade, South bO" 0O' 00" West 231.46 feet to ~ ~int; ~ R~N~ im a southerly direction alo~ the westerly line of ~he land of Alert M. ~arbade and B. O. ~ee, South 24" OO' ~0' East a distan~ of 572.89 f~t ~o m ~int ~ated on the northerly side of the land n~ or fo~er~y of ~cas '~E R~{X~ in a ~sterly dir~tion ,1~ the northerly li~ of the land n~ or fo~aerly of Lucas Pontino, South 61" 21' 1)" West 319.86 feet to a co~rete monument~ ~{CE R~X~ in s northerly direction alo~ the easterly line of ~he land n~ or formerly of Koroleski, North 21~ 47' 1O' west 1266.95 feet to a point l~ated on th~ southerly side of Main R~d (Route 25); ~E R~ in a ~rtheasterly direction alo~ the southerly side of Main Road (Route 25) N~th 46· 35' 20" East 521.59 feet to the concrete monument; the ~int or place of SUBJECT TO any state of facts an accurate survey may show provided same does not render title unmarketable. SUBJECT TO covenants, restrictions, reservations, utility eas4~ments and agre~muents of record, if any, provided same does not prohibit the maintenance end use of the present structure o~ said demised land, if any. This sale includes all right, title and interest, if any, of the seller in and to any land lying in the bed of any street, road or avenue opened or proposed, in front of or adjoining said premises, to the center line thereof, and all right, title and interest of the seller in and to any award made or to be made in lieu thereof and in and to any unpaid award for damage to said premises by r~ason of change of grade of any street; and the seller will execute and deliver to the purchaser, on closing of title, or thereafter, on demand, all proper instruments for the conveyance of such title and the assignment and collection of any such award. The pfis. k Dollars. payab~e~nw Dollar on the signing of this contract, by check subject to collection, the receipt of which is hereby a~,,'t~dged; ~ Dollar in cash or good certified check on the delivery of the deed as hereinafter p~ by taking title subject to a mortgag~n on saicl premises in that amount, bearing interest at th rate of per cent per annum, the pn~tte and payable Dollars by the purchaser or assigns exec~.i~~ng tothe seller a bond or, at the option of the seller, ~ Any bond or note and mortgage to be given hereunder shall be drawn on the standard forms of New York Board of Title Underwriters for mortgages of like lien; and shall be drawn by the attorney for the seller at the expense of the purchaser. who shall also pay the mortgage recording tax and recording fees and pay for and affix to such instruments any and all revenue stamps that may be necessary. F{~'O fO~' $~:'i.I.¢}~*..q .~k.~O~eiqey .~]:~,~.l. riO'?. O3.:e~:~cJ ~0C If such purchase money mortgage is to be a subordinate mortgage on the premises it shall provide that it shall be subject and subordinate to the lien of the existing mortgage of $ , any extensions thereof and to any mortgage or consolidated mortgage which may be placed on the premises in lieu thereof, and to any extensions thereof provided (a) that the interest rate thereof shall not be greater than per cent per annum and (b) that. if the principal amount thereof shall ~xceed the amount of principal owing and unpaid on said existing mortgage at the time of placing such new mortgage or consolidated mortgage, the excess he paid to the holder of such purchase money mortgage in reduction of the principal thereof, Such purchase money mortgage shall also provide that such payment tn the holder thereof shall not alter or affect the regular installments, if any. of principal payable thereunder and shall further provide that the holder thereof will, on demand and without charge therefor, execute, acknowledge and deliver any agree- ment or agreements further ~:o effectuate.such subordination. If there be a mortgage on the premises the seller agrees to deliver to the purchaser at the time of delivery of the deed a proper certificate executed and acknowledged hy the holder of such mortgage and in form for recording, certifying as to the amount of the unpaid principal and interest thereon, date of maturity thereof and rate of interest thereon, and the seller shall pay the fees for recording such certificate. Said premises are sold and are to be conveyed subject to: I. Zoning regulations and ordinances of the city, town or village in which the premises lie which are not violated by existing structures. 2. Consents by the seller or any former owner of premises for the erection of any structure or structures on, under or above any street or streets on which said premises may abut. 3. Encroachments of stoops, areas, cellar steps, trim and cornices, if any, upon any street or highway. Cit~ of All notes or notices of violations of law or municipal ordinances, orders or requirements noted in or issued by the Depart- ments of Buildings, Fire, Labor, Health, or other State or Municipal Department having jurisdiction, against or affecting the premises at the date hereof, shall be complied with by the seller and the premises shall be conveyed free of the same, and this provision of this contract shall survive delivery of the deed hereunder. The sellex shall furnish the purchase~' with an authorization to make the necessary searches therefor. If, at the time of the delivery of the deed, the premises or any part thereof shall be or shall have been affected by an assess- ment or assessments which are or may become payable in annual installments, of which the first installment is then a charge or lien, or has been paid, then for the purposes of this contract all the unpaid installments of any such assessment, including those which are to become due and payable after the delivery of the deed, shall be deemed to be due and payable and to be liens upon the premises affected thereby and shall be paid and discharged by the seller, upon the delivery of the deed. The following are to be apportioned: (t-)-Rent~ as and wh~ttected. (2) lnte,~st .m mo, tgas.-s. (3) Premiums on exbting traasferahk insaranec polielcs or ren~,s, ats of those-expi~hig prlc. i to thtebslm~. (4) Taxes and sewer rents, if any. on the basis of the fi~cal ye.~ for which assessed. (5)A~at.~ chazs~ vu the b,:~i~ ~gf the ,~h.d,,r · if the closing of the title shall occur before the tax rate is fixed, the apportionment of taxes shall be upon the basis of the I lax rate for Ihe next preceding year applied to the latest assessed valuation. ]if there be a water meter on the premises, the seller shall furnish a reading to a dale not more than thirty days prior to the 'time herein set tot closing title, and the unfixed meter charge and the unfixed sewer rent. if any, based thereon for the intervening time shall be apportioned on the basis of such last reading. deed in proper stalutow short form for record and shall be duly executed, acknowledged, and have revenue stamps in t~e pro~ amount a~xed thereto by the seller, at the seller's expense, so as to convey to the purchaser the fee simple of the said premises, free of all encumbrances, except as herein stated, and shall also contain the covenant required by subdivision 5 of Section 13 of the Lien Law. amount of the ~eal Pro~rty Transfer Tax im~sed by Title I of Chapter 46 of the Admlni~t~-t}~ Code o[ the ~lty of New York and will also deliver to the purchaser the return ~eauired ky thc ~id ~thtute and the repletions issued pursuant to the authority thereof, duly signed ann ~v~.~ to b~ the sel~er; the purchaser agrees to s{~ and swear t~ the said return and to , ~ ..... L ' ' 'and th. ~ald rellim lo he delivered to ~ho City Revi~ter nromnllv after the clnsin~ of the title. ~ ~t~a~ ~v~.~3he ourcha~r shall accept a title such as , a Member of the New York Board of Title Underwriters, will approve and insure. All sums paid on account of this contract, and the reasonable expenses of the examination of the title to said premises and of the survey, if any, made in connection therewith are hereby made liens thereon, but such liens shall not continue after default by the purchaser under this contract7 sented to be owned by the seller, free from all liens and encumbrances except ahs ereln stated, a ' n ~s sale; without limiting the generality of the foregoin~y ~clude plumbing, heating, lighting and cooki~~'a!s, bathroom and kitchen cabi or mirrors, venetian blinds, shades, screens, awnings, storm windows, w/ndow boxes, storm The amount of any unpaid taxes, assessments, water charges and sewer rents which the seller is obligated to pay and discharge, with the interest and penalties thereon to a date not less than two business days after the date of closing title, may at the option of the seller be allowed to the purchaser out of the balance of the purchase price, provided official bills therefor with interest and penalties thereon figured to said date are furnished by the seller at the closing· If at the date of closing title there may be any other liens or encumbrances which the seller is obligated to pay and discharge, the seller may use any portion of the balance of the purchase price to satisfy the same, provided the seller shall have delivered to the purchaser at the closing of title instruments in recordable torm and sufficient to satisfy such liens and encumbrances of record, together with the cost of recording or filing said instruments. The purchaser, if request is made w/thin a reasonable time prior to the date of closing of title, agrees to provide at the closing separate certified checks as requested, aggregating the amount of the balance of the purchase price, to facilitate the satisfaction of any such liens or encumbrances. The existence of any such taxes or other liens and encumbrances shall not be deemed objections to title if the seller shall comply with the foregoing requirements· If a search of the 6tle discloses judgments, bankruptcies or other returns against other persons having names the same as or simiIar to that of the seller, the seller will on request deliver to the purchaser an affidavit showing that such judgments, bank- rupt,'ies or other returns are not agaimt the seller O;' If ~J.~O ~L£ i-ll£1~ih",'lb.l.O ~, '[~}10 t.i"'..~_r~ t O. in the event that the seller is unable to convey title in accordance with the terms of this contraS, the sole liability of the seller will be to refund to the purchaser the amount paid on account of the purchase price and to pay the net cost of examining the title, which cost is not to exceed the charges fixed by the New York Board of Title Underwriters, and the net cost of any survey made in connection therewith incurred by the purchaser, and upor~ such refund and payment being made this contract shall be considered canceled. Th~..d.e,ed~ ~e delivere4 upon the receipt of ~id payments at the off:ice of ,, ~ ,~-:.,~ .~, 2 P.H. ' ' '~'~ '1~ The parties agree that brought about this sale and the seller agrees to pay the commli~ion at.tl~ r'tal~ B~ks~c m th~ locality w, horo tho pre~ty ts ~u-t_8, It is understood and agreed that all understandings and agreements heretofore had between the parties hereto are merged in this contract, which alone fully and completely expresses their agreement, and that the same is entered into after full investigation, neither party relying upon any statement or representation, not embodied in this contract, made by the other. The purchaser has inspected the buildings standing on said premises and is thoroughly acquainted with their condition. This agreement may not be changed or terminated orally. The stipulations aforesaid are to apply to and bind the heirs, executors, administrators, successors and assigns of the respective parties. · If two or more persons constitute either the seller or the purchaser, the word "seller" or the word "purchaser" shall be construed as if it read "sellers" or "purchasers" whenever the sense of this agreement so requires. IN WITNESS WHEREOF, this agreement has been duly executed by the parties hereto. ,' In presence of: HOT'E: FIRE LOSSES. This form of contract contaios no express provision as to risk of loss by fire or other casualty before delivery of the deed. Unless express provision is made, the prov/sions of Section 5-1 311 of the General Obligations Law w/Il apply. This section also places risk of loss upon purchaser if title or possession is transferred prior to closing. RIDER ANNI'iXED TO CONTRACT OF SALE BETWEEN ALBERT A. SACCO AS SELLER AND LOUIS ZAINO AND ARMANDO SARDELLI AS PURCHASERS FOR THE PURCHASE OF LAND LOCATED AT PECONIC, TOWN OP S(~J[aiOLD, CCA;q~TY OF SUFFOLK, STATE OF NEW YORK, DATED %~{E 2~th DAY OF APRIL, i970. 1. The price is Eighty Thousand ($80,000.00) payable as follows= Eight Thousand ($8,000.00) Dollars on the signing of this eontract by~,heck or checks subject to collection the receipt of which is hereby acknowledged; Fifteen Thousand Two Hundred ($15,200,00) Dollars in cash or good certified check on the delivery of the deed aa hereinafter provided; prepay without thereof. Fifty-six Thousand Eight Hundred ($56,800.00) Dollars by the purchasers or assigns executing, acknowledging and delivering to the seller a bond or at the option of the seller a note secured by a purchase money first mortgage on the above premises/land, in that amount, payable five (5) years from date of closing; together with interest at the rate of 6% payable quarter-annually;interest! only shall be payable during the first two (2) years of this mortgage; thereafter, in addition to said quarter-annual installments of interest, principal reductions of Four Thousand Seven Hundred Thirty-three and 33/100 ($4,733.33) Dollars each shall be paid et the beginning of the third, fourth and fifth years of this mortgage, quarter- annually. Purchasers shall have the right at any time to penalty the said mortgage in whole or any part 2. That the dow~ payment made herein .i by the 9urchssers to the seller in the amount of Eight Thousand ($8,000.0C) Dollars shall be held in escrow by the attorney for the seller Pending title closing. 3, It is ~derstood between the parties hereto that the seller is under an oral lease and arrangement with one Frank Chicanowicz, Jr., residing at Route 25, Peconic, New York, wherein the said Frank Cichan~wicz, Jr. is presently leasing approximately, but not more than, twelve (12) acres of the herein demised land for the purpose of growing sod. That the sale herein between the seller and purchasers is further subject to the present tenant entering into and ~xecuting a written lease with the purchasers herein simultaneous with the execution of the deed herein and passage cf title wherein and whereby the said tenant shall continue to lease the aforementioned acreage .for the same purpose at the price of Fifteen Hundred ($1509.00) Dollars per year (at the rate of $125.00 per acre per year) for i'ia term not exceeding or extending beyond October 15, 1972. In the event that the said tenant shall refuse ko enter into such agreement for reasons best known to himself, then ~in that event, the sale herein is subject to the seller herein obtaining an executed document from the said tenant wherein the 'tenant relinquishes all right, title and interest in and to the demised premises, tenancy and use thereof; that the said tenant shall thereupon vacate and remove from the demised premises 'together with the existing sod crop, if any, on or before but in no event not later than October 15, 1970, time being of the essence; that the tenant shall continue to psy to the purchasers :herein upon them having taken title to said demised land/premises, the rental as same may be adjusted at the rate of $125.00 per ~acre per year up to 8nd including October 15, l~7iJ. This pro- iivision shall survive the closing of title herein. 4. If any past due rentals are due and owing by the tenant at the time of closing of title the same shall not be considered an item of adjustment to be made herein and there shall be no obligation upon the purchasers to collect same for and on behalf of the seller. 5. The seller agrees that he will not enter into ~i,ny leases or other agreements, oraL'or in writing, for the i~leasing, occupancy, tenancy of the demised land/premises between ~the time of executing the within instrument and the time of cl°sing' 6. The mortgage shall provide that during the term of the mortgage herein the purchasers shall not arbitrarily remove the top soil from the land/premises or the stripping thereo~ except that if in the event purchasers elect to build or construct on any part or portion of said premises or to sell any portion ~of said land/premises for the purposes of construction, then, iin that event, the top soil may be removed ~nd wherever feasible ~ito be moved or spread about fr~ place to place on the remaining !I unia%proved land. 7. The seller hereby represents and warrants that the premises herein being demised, that portion thereof set on the Main Road for a distance of 521.49' to a depth of 200', are zoned "B" Business under the Southold Town Zoning Ordi~ance. ~The seller further represents and warrants that as to the remain- !ing portion of the premises covered by this contract, said pr~uise~ are zoned "A" Agricultural and Residential under the Southold iTown Zoning Ordinance. ,, 8. The parties further agree that the purchasers iihave the right of assig~ent of this contract to any other person iior corporation subject to having the seller notified within ten !(10) days prior to such assignment. 9. It is further agreed that the purchasers~ {~ortgagors have the right at any time following passage of titl~ iherein to use,maintain, build, constr~%ct and do ~hstever purchasers ilmay desire with said property without any interference, objection !lot restriction by the seller as long as same does not depreciate ithe property and is in accord with the applicable zoning and ~municlpal ordinances or laws. -2- 10. That the o%v~r, seller or authority of this mortgage wil~ upon request and without cost, execute, mcknowledge and deliver instrt~ents in order to effectuate the following, if necessary: i. Consent to the submission and filing of s map and to the filing of subdivisions of said map as may be required by the municipal authoritie~ having Jurisdiction over the m~pping of the acreag~ ii. Con~ent and subordinations to the filing of usual easements for the installation of public utilities, including gas, water, electricity and telephone, on the streets and along lot lines, and for dedication of street areas, park areas and drainage. iii. Consent and subordinations to the filingl of the protective covenants and restrictions which may be required by duly licenses financing in- stitutions as a condition precedent to issuing any mortgage on the land or to the insuring of mortgage loane which may affect the mortgaged premises. 11. That the mortgage shall contain a clause as well as the bond or note thereunder which it secures in the within contract. That it shall not obligate the mortgagors further~ than Ito bind their right, title and interest in the mortgaged premises and on any default thereunder, no deficiency or other personal li jud~-gment shall be rendered or entered against the mortgagors. ALBERT A. SACCO, Seller i LOUIS ~AINO, ~-urchaser '~ -3- Armando Sardelli, Purchaser TO: TItM SOUTHOLD TOWN BOARD and THE SOUTHOLD TOWN ZONING BOARD OF APPEALS The undersigned, as residents of the Town of Southold, object to and protest the proposal to amend the Building Zone Ordinance (includtnE the Building Zone Maps) by changing from "A" Residential and Agricultural District to "B-l" General Business District the property of Louis Zaino and Arr~u~do Sardelli situated at the corner formed by the inter- section of the southerly side of Main Road (Rt. 25) and the westerly side of Indian Neck Lane~ Peconic. TO: 'i~ SOUTHOLD TOWN BOARD and THE SOUTHOLD TOWN ZONING BOARD OF APPEALS The undersigned~ as residents of the Town of Southold, object to and protest the proposal to amend the Building Zone Ordinance (inclua~ng the Building Zone Maps) by chan~ing from "A" Residential and Agricultural District to "B-l" General Business District the property of Louis Zaino and Armando Sardelli situated at the corner formed by the inter- section of the southerly side of Main Road (Rt. 25) ~nd the westerly side of Indian Neck Lane, Peconico -~ t_Y/~ .. ? ~ U TO: '~ SOUTHOLD TOWN BOARD and THE SOUTHOLD TOWN ZONING BOARD OF APPEALS The undersigned, as residents of the Town of Southold, object to and protest the proposal to amend the Building Zone Ordinance (including the Building Zone Maps) by changing from "A" Residential and Agricultural District to "B-l" General Business District the property of Louis Zaino and Armmndo Sardelli situated at the corner formed by the inter- section of the southerly side of Main Road (Rt. 25) and the westerly side of Indian Neck Lanej Peconic. TO: 'l~ SOUTHOLD TOWN BOARD and TI~ $OUTHOLD TOWN ZONING BOARD OF APPEALS The undersigned, as residents of the Town of Southold, object to and protest the proposal to amend the Building Zone Ordinance (inclua~ng the Building Zone Maps) by changing from "A" Residential and Agricultural District to "B-l" General Business District the property of Louis Zaino and Armando Sardelli situated at the corner formed by the inter- section of the southerly side of Main Road (Rt. 25) and the westerly side of Indian Neck Lane, Peconic. TO: Tt~ SOUTHOLD TOWN BOARD and THE SOUTHOLD TOWN ZONING BOARD OF APPEALS The undersigned, as residents of the Town of Southold, object to and protest the proposal to amend the Building Zone Ordinance (including the Building Zone Maps) by changing from "A" Residential and Agricultural District to "B-i" General Business District the property of Louis Zaino and Armando Sardelli situated at the corner formed by the inter- section of the southerly side of Main Road (Rt. 25) and the westerly side of Indian Neck Lane, Peconic. TO: 'l~ SOUTHOLD TOWN BOARD and THE SOUTHOLD TOWN ZONING BOA.RD OF APPEALS The undersigned, as residents of the Town of Southold, object to and protest the proposal to amend the Building Zone Ordinance (inclu81ng the Building Zone Maps) by changing from "A" Residential and Agricultural District to "B-l" General Business District the property of Louis Zaino and Armando Sardelli situated at the corner formed by the inter- section of the southerly side ofMain Road (Rt. 25) and the westerly side of Indian Neck Lane, Peconic. NOnCa OP ~s~a o~ ZO~IN60lml~ANCE Pursu~t {i~ $~ion/2~ of the Town ~t and' ~eq~i~mems of :the B~ilding ~ne ~dinance of t~e Town of ~uth~d. Suffolk County. ~w York. public hearing ~l be h~ by the ~uthold Town ~r~ in i~e Offwe of the S~per- ~r, 16 ~uth itree/,,Green~, ~ew York, in said Town. ~ the 27th;day of August~ 1974, on the ~ttowing pm~sal to amend thc ~iiding Zone O~di~ance (includ- i~ the, B~lding~ne Maps) d the Town of Southold, Suffolk C~nty, New York. s~ P,~,i~;D.S.T.) by chang- ~t~~ ~A ~ R~ia[ and ~ ~&i~es, oiS~d~ ma pro- ~L~uis Zai~o and Armando :Sardelli situated at Peconlc. Town County, New ~ , pl~rticalarl~ as fol- c~mer formed by th [ the southerly Rolul ,(.Route 25).a~i ' ride of ~d~an ~ [ outh 24~00' 00" I~st tl~e ~vester- ly ~'side Qf ~ttan ~, Lane a dlStazce ~ 212.~5 ~t ~[~ S point located on the northe~t, ci~'~er of , the laid, npw of ~ ~ and A~an~ S~delli~ ~ ~n- ning in a.~uthw~ly, d~n t~d alOns· s~utherly now of Louis Zaino~[ S~'rdelli South 46e~ S~,4i feet to a~ ~ing in a along the easterly n~ or formerly No~h 21~47' 10" W~t Indo ~rest land ~raleski ,~14 feet to a point located on the southerly side of Main Road~ (Rdute 25); thence running in a northeasterly direction along the southerly side ~[ Main Road (Route 2S) North 46 3fi' 20" East 521.$9 feet to the concrete monument, the point place of BEGINNING. Any person desiring to he, heard on ~the above proposed amendment should appear at the time a~d place so specified. DATED: August 12, 1974 BY ORDER OF THE SOUTHOLD TOWN BOARD ALBERT W. RICHMOND, ~--TOWN CLERK IT, 8/15 COUNTY OF SUFFOLK [, ss: STATE OF NEW YORK C. \¥hi~,.L~f2~}J~,, ,rl~.~ being duly sworn, says that he is the Editd/,r~ff.o~'~'jzlE LONG ISLAND TRAVELER - MA'I-FITUCK WATCHMAN, a public news- paper printed at Southold, in Suffolk County; and that the notice of which the annexed is o printed copy, has been published in said Long Island Zraveler-Mattituck Watch- man once each week for .....~./~.'Z:'£.-~....-.(-.Z'f'.' weeks ' successively, commencing on the ............ of ......... ......... , . ..~:t~::.x~..~:.~ .....;/ ....... ::..:::.....~) ..................... Sworn fo before me this ....... .~/~ ......... do'/ of ....... ....... y / ..... ......... .................. '~-o'~ ~,~,~ NOTICE OF ItEARINC~ ON PROPOSAL TO AME~ ZONII~ Olml~CE ~ tO ~85 of the the Su~,g ~ce of the l'own~ o~ SUffolk County, heari~ will t the SouthOld '~ the b~ 1" Ge~ral Busim~ District the P~~is Zaino and ~~ ~t~t~ at Peco~ ~of Southold, m~ ~] ~ ~d ~um~ly ~ ~ ~n ~d (~ ~) ~d q ~ly side of ~ s~ ~; ~ee ~u~ ~ d~,~" ~st ~o~ ~ w~ly~ d h~an no~t ~ ~ me ~w of ~s ~d ~ soumw~rly ~ction ~ong a ~utherly l~e of ~e l~d now of COUNTY OF SUFFOLK, STATE OF NEW YORK, ~ ss: Stuart C. Doman being duly Sworn, says that . .h..e... is Printer and Publisher o! the SUFFOLK WEEKLY TIMES, a newspaper published at Greenport, in said county; and mat the notice, of which the ~v~nex~ed is a printed copy, has been published in the said Suffolk Weekly Times once in each week, tar ..... one ( 1 ) weeks succ~ssive~y~m~S on me .......... .~.~.~..h day · · Sworn to before me this ....~.~.h... d~ ~ ~ ~' ~o"....~~ _-,al~ ~ ,.,V~ d~on / ~6: ~":l[?'.~'~'~ '~u~f,l'S£N~) .... ~o" West m. '~.t,~., pant r-mtfng tit a' no~gleasterly of ~ Road (Route ~) North ~ de~re~s ~' ~0" ~st ~1.59 feet to the concrete monument, tile point or place o( BEG1NIqlNG, .amy per~ des~ to be heard on the above proposed amend- ment should appear at the time and place so specified. DATED: A~ust 12, l~q4 BY OPE)ER OF ~ SOUTIiOLD TOWN BOARD Al,BERT W. RICHMOND, TOWN CLERK STATE OF NEW YORK: COUNTY OF SUFFOLK: SouthoLd, New York, SS: ALBERT W. RICHMOND, being duly sworn, age of twenty-one years; that o~ the 1974 he affixed a notice of which is ~ true copy, public place in York, to wzt:- in a proper and substantial ~an?e~ the Town of Southeld, Suffolk Conn.? Legal Notice Change of Zone Hearing Zaino & Sardelli 8:00 P.M. - August 27, 1974. Town Clerk Bulletin Board, Town Clerk Main Ro~d, Southold, LoI.,N.~'~. Sworn to before me this 20th day of August Albert W. Richm{~nd, '~own .'} r}< i9 74 ,H T £CKFH LEGAL NOTICE NOTICE OF HEARING ON PROPOSAL TO AMEND ZONING ORDINANCE Pursuant to Section 265 of the Town Law and Requirements of the Building Zone Ordinance of the Town of Southold, Suffolk County, New York, public hearing will be held by the Southold To%~n Board in the Office of the Supervisor, 16 South Street, Greenport, New York, in said Town, on the 27th day of August, 1974, on the following proposal to amend the Building Zone Ordinance (including the Building Zone Maps) of the Town of t Southold, Suffolk County, New York. 8:00 P.M. (E.D.S.T.) by changing from "A" Residential and tAgricultural Distric~ to "B-I" General Business District the property of Louis Zaino and Armando Sardelli situated at Peconic, Town of Southold, Suffolk County, New York, and more particularly bounded and described as follows: BEGINNING at the corner formed by the intersection of the southerly side of Main Road (Route 25) and the westerly side of Indian Neck Lane; thence south 24" 00' 00" East along the westerly side of Indian Neck Lane a distance of 212.05 feet to a point located on the northeast corner of the land now of Louis ~aino and Armando Sardelli; thence running in a southwesterly direction along a southerly line of the land now of Louis Zaino and Armando Sardelli South 46" 35' 20" West 530.41 feet to a point; thence running in a northerly direction along the easterly line of the land now or formerly of Rose Koraleski North 21" 47' 10" West 215.14 feet to a point located on the southerly side of Main Road (Route 25); thence running in a northeasterly direction along the southerly side of Main Road (Route 25)North 46° 35' 20" East 521.59 feet to the concrete monument, the point or place of BEGINNING. Any person desiring to be heard on the above proposed amendment should appear at the time and place so specified. DATED: August 12, 1974 BY ORDER OF THE SOUTHOLD TOWN BOARD ALBERT W. RIChmOND, TO~ CLERK Legal Notice Page 2 PLEASE PUBLISH ONCE, AUGUST 15, 1974, AND FORWARD FOUR (4) AFFIDAVITS OF PUBLICATION TO THE SOUTHOLD TOWN CLERK, MAIN ROAD, SOUTHOLD, NEW YORK. Copies mailed to the following on August 12, 1974: The Suffolk Weekly Times The Long Island Traveler-Mattituck Watchman Supervisor Albert M. Martocchia Irving I. Miller, Esq. NORTH FORK ENVIRONMENTAL COUNCIL, INC. Box 311, Soufhold, New Yorl~ 11971 August 27,1974 Southold~ Town B~ard S~uth Stree~ Gr~e~po r~, New~ York Gentlemen: In regard to the ~]~lication of Lomis Zaino. and Armando Sardelli, for a~, change of zone from A to B1, location: Indian Neck Lane and Main Road Peconi~, New Yo, rk, The North l%rk Environmental Council g~rongly opposes the granting 0'3 this~ change for' the following reasons: 1. The Master' Plan shows this property to be A-R and we feel this plan. must be followed for' orderly growth in Southold Town. 2. We feel the granting of this would be "spot zoning" and change the charaoter of the area, one ~ ' ' .~we~ is ~1~ one of the finest A~-residential area~in Southold Town~ 3. Again we feel that a change of zone without restrictions could produce numbers of problems as there is no guarantee as to the business that would be placed there if the owners plans change or that the property changes hands. We; do therefore urge you to deny this application~ Sincerely, Loraine S. Terry,Pres. N~EC COMMISSION Seth A, Hubbard Chairman Lee E. Koppelman Suffolk County Department of Planning Veterans Memorial Highway JOHN V.N. KLEIN, County Executive Ha~pFa~ge, L. L, N. Y. 979-292O August 5, 1974 Mr. Albert W. Richmond, Town Clerk Town of Southold Main Road Southold, New York 11971 Re: Application of "Louis Zaino and Armando Sardelli" for a proposed change of zone from "A" Residential to "B-i" Business, Town of Southold (SD-74-10) Dear Mr. Richmond: Pursuant to the requirements of Sections 1323 to 1332 of the Suffolk County Charter, the Suffolk County Planning Commission has reviewed the above captioned zoning action and has disapproved this change of zone because of the following: 1. It is inconsistent with the Town Master Plan which designates this area for residential development; 2. It is inconsistent with the pattern of zoning in the locale and there- fore must be considered as "spot zoning"; 3. It would tend to establish a precedent for the further perpetuation of undesired strip commercial development along Rte. 25; and 4. It is inconsistent with the residential character of the surrounding Very truly yours, Lee E. Koppelman Director of Planning Gerald G. Newman Chief Planner GGN:fp Southold Town Planning Board E~OUTHOLD, L. I., N. Y. 11971 PLANNING BOARD MEMBERS John Wickham, Chairman Henry Molsa Alfred Grebe Henry Raynor Frank Coyle July 10, 1974 Southold Town Board 16 South Street Greenport, New York 11944 Gentlemen: The following action was taken at a regular meeting of the Southold Town Planning Board held on July 8, 1974. On motion made by Mr. Wickham, seconded by Mr. Raynor, it was RESOLVED that the Southold Town Planning Board recommend to the Southold Town Board denial of the petition of Louis Zaino and Armando Sardelli requesting a change of zone on certain property situated at Peconic, New York, from "A"~Residential and Agricultural District to "B-l" General Business District. This petition seems to be based on the illegality of the zoning law. To the best of the knowledge and belief of the Southold Town Planning Board the zoning laws of the Town of Southold are constitutional and were adopted after due process and the Southold Town Planning Board feels that the existing use of the property as zoned is correct. Vote of the Board: Ayes: Wickham, Raynor, Coyle, Moisa. Absent: Grebe. Yours truly, Southold Town Planning Board Town Of Southold TOWN CLERK 765-378.3 Building Dept. l Planning Bd. 765-2660 Board of Appeals TOWN CLERK'S OFFICE Main Road Southold, N. Y. 11971 Pursuant to the C~eneral M'unicipal Law, Chap+er 24, of the Consolidated Laws, Article 12-B, Sections 23%1 and m, the ~ ~ of the town of Southold, N. Y. hereby refers the following (agency involvedI proposed zoning action to the Suffolk County Planning Commission: [check one) New and recodlfied zoning ordinance Amendment to the zoning ordinance Zoning changes Special permits Variances Location of affected land: within 500 feet of: (check one or moreI Town or village boundary line State ~ road, J)~,~l~)t,~- State or county park or recreation area Stream, or drainage channel owned by the county or for which the county has established channel lines ....... State or county owned parcel on which a public building is situated (signed) Title Date recelved by Suffolk County Plenning Commission ......................... Fib No ALBERT W. ~I~HMFIND nFF~ERK SE}UTHnLD, L. I, N. Y, llCJ?l June 19, 1974 Mr. John Wickham, Chairman Southold Town Planning Board Cutchogue, New York 11935 Dear Mr. Wickham: The original petition of Louis Zaino and Armando Sardelli requesting a change of zone on certain property situated at Peconic, New York, from "A" Residential and Agricultural District to "B-l" General Business District is in the files in the office of the P~nning Board at Southold, New York. You are instructed to prepare an official report defining the conditions described in the petition and determine the area so affected with the recommendation of your Board. Very truly yours, Albert W. Richmond Town Clerk Mr Irving Miller~ Attorney 832 Pepperidge hoad Westbury, N.i. 11~90 June 10, I Dear Sirs Receive~ i'ro~ the 'Aown Clerk today~ your aopiication A/C Loui~ ~u~o ~k ~rmando Sardelii fro eh~ge of zone from ".~,' to "B-I"~ appeal ~ 225. Recei~t for fee $ 100~00 enclosed. This will be forwareed to the Town Bosrd on June 18th and refferred to the Planning Board for processing. louts truly BuiidinE inspector ~ 1AW OFFICES IRVINO I. MILLER CERTIFIED MAIL RETURN RECEIPT REQUESTED PEPPERIDGE ROAD P. O. BOX 529 WESTBURY, NEW YORK 11590 ~16 - 333-2930 June 7, 1974 Clerk, Town of Southold Main Road Southold, N.Y. 11971 Dear Sir: On behalf of Louis Zaino and Armando Sardelli, enclosed herewith please find six duly executed copies of application for modification of zoning of that portion of the property more specifically identified in the shaded area on the attached maps. Also in conformance with the application, please find six copies of maps as prepared by Roderick Van Tuyl, P.C., Greenport, N.Y., dated May 8, 1974, as well as general contour maps of similar date. Accompanying the application herein is my check in the amount of $100.00, representing the requisite fee. Would you please be good enough to acknowledge receipt and advise as to the date of hearing. Thank you for your courtesy and cooperation. Very truly yours, IIM/rr Enc. CASE NO: ....................... STATE OF NEW YORK PETITION TOWN OF SOUTHOLD IN THE MATTER OF THE PETITION OF LOUIS ZAINO and ARMANDO SARDELLI FOR A C1L~NGE, MODIFICATION OR AMENDMENT OF THE BUILDING ZONE ORDIN- ANCE OF THE TOWN OF SOUTHOLD, SUFFOLK COUNTY, NEW YORK. TO T~E TOWN BOARD OF THE TOWN OF SOUTHOLD: LOUIS ZAINO 10 Terrace Ct., Old Westbury, 1. ~ ...~P~MA~DO...~ARD]~LL~ ....................... , residing at ]~.9...~..1..v..e..]$~..r..d....L~..,..,...}I.~.~.i~gton, (insert name of oetitioner) r e spec~ lve-y, a r e Nassau & S~ffolk County, New York/the undersigned, ~f~ the owne~of certain re~l proper~y situated at ............. ~..e..c_9.n..i_c. ............................... and more particularly bounded and described as follows: BEGINNING at the corner formed by the intersection of the southerly side of Main Road (Route 25) and the westerly side of Indian Neck Lane; thence South 24° 00'00" East along the westerly side of Indian Neck Lane a distance of 212.05 feet to a point located on the northeast corner of the land now of Louis Zaino and Armando Sardelli; thence running in a southwesterly direction along a southerly line of the land now of Louis Zaino and Armando Sardelli South 46° 35'20" West 530.41 feet to a point; thence running in a northerly direction along the easterly line of the land now or formerly of Rose Koraleski North 21° 47'10" Wast 215.14 feet to s point located on the southerly side of Main Road (Route 25); thence running in a northeasterly direction along the southerly side of Main Road (Route 25) North 46° 35'20" East 521.59 feet to the concrete monument, the point or place of beginning. 2. I do hereby petition the Town Board of the Town of Southold to change, modify and amend the Building Zone Ordinance of the Town of Southold, Suffolk County, New York, including the Building Zone Maps heretofore made a part thereof, as ~o]lows: To ~einsta fie the zoning classification of that portion of the real property more particularly identified, situated and described by the attached maps dated May 8, 1974 msde by Roderick Van Tuyl, P.C., Greenport, New York, relating to the area fronting on Main Road at the intersedtion with Indian Neck Road constituting 2.415 acres as shaded on said map from "A" to "B-l" being the original classification of zone for that portion of the premises, heretofore had prior to the enactment of the Southol~ Town Zoning Ordinance of November 23, 1971. 3. Such request is made for the following reasons: 1) The statutes which create the authority to have permitted the enactment of the Southold Town ~oning Ordinance of November, 1971 were unconstitutional, arbitrary and unreasonable; 2) the enactment of the Southold Town Zoning Ordinance of 1971 was in violation of the constitutional rights of the petitioners herein; 3) that the present zoning classification is an invasion of the petitioners' legal and constitutional rights to own and put the property to its high~st and best use; 4) that Petitioners were caused to suffer significant economic injury by the application of the (Continued on next page) existin,q zoning ord2 ze which was not justifi nd was in fact not in any ~ai,~el harmful to the public health, safety and welfare; 5) that the enactment of the said zoning ordinance was an abuse of discretion as a matter of law and equity; 6) that the present classification is consistent with spot zoning in violation of petitioners' rights; 7) that the rezoning constituted a confiscatory act on the part of the Town with deprivation of rights, consti- tutional and civil, of petitioners herein; 8) that the change of zoning enact- ment was committed without proper and due notice to petitioners; 9) that the enactment is in violation of the equal protection clause of the United States and New York State constitutions and in violation of the exercise of police power and authority; i0) that thc enactment and enforcement of the present classification of the property does not serve a legitimate public interest; 11) that the enactment and rezoning was without comprehensive planning and impacted to effectuate the present result against these petitioners specifically. Memorandums of Law substantiating petitioners' position on all of the foregoing will be submitted upon the acknowledgement of the within application and prepared for argument at the hearing. STATE OF NEW YORK,) NASSAU COUNTY OF SI~I~](~,,) LOUIS ~,AINO and · AP~4A~..~[4I~I ...................... , BEING DULY SWORN, depose~and say~ that are t h~,'i~ the petitione~Sin the within action; thatth~t~ h~ eread the foregoing Petition and knov~ the ~r the contents thereof; that the same is true to~o~) own knowledge, except as to the matters therein stated to be alleged on information and belief, and that as to those matterstheybelieves it to be true. (L s-X '..~. ,~.. ~~ Sworn,~re me this5th ,/ . - June 74 · ?-ffey ot . . ./~ ................... 19 .... AIN ROAD /