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Resolution No. 2022-58 Approving Amended Declaration of Restrictions (2751 NE 183 St. and 2777 NE 183 St.) - September 13, 2022 CITY OF AVENTURA RESOLUTION NO. 2022-58 A RESOLUTION OF THE CITY OF AVENTURA, FLORIDA, APPROVING AN AMENDMENT TO THE DECLARATION OF RESTRICTIONS RELATED TO THE PROPERTIES LOCATED AT 2751 N.E. 183RD STREET AND 2777 N.E. 183RD STREET TO REMOVE THE LEASE RESTRICTION; PROVIDING FOR IMPLEMENTATION; AND PROVIDING FOR AN EFFECTIVE DATE. WHEREAS, Imperial Owner owns the property located at 2751 N.E. 183rd Street in the City of Aventura (the "City") that is improved with a fourteen-story senior living facility known as the Imperial Club (the "Imperial Club"); and WHEREAS, Sterling Owner owns the property located at 2777 N.E. 183rd Street in the City that is improved with an eight-story assisted living facility known as the Sterling (the "Sterling"); and WHEREAS, in connection with obtaining certain development approvals from Miami-Dade County (prior to incorporation of the City) with respect to the development of the Imperial Club and the Sterling, the predecessors in title of such properties executed a Declaration of Restrictions, dated November 16, 1990, recorded on January 23, 1991 , in Official Records Book 14867, Page 1252 of the Public Records of Miami-Dade County (the "Declaration"); and WHEREAS, the Imperial Club and the Sterling comprise the property subject to the Declaration, as legally described in Exhibit A to the Declaration; and WHEREAS, paragraph four (4) of the Declaration prohibits the owner of either the Imperial Club or the Sterling from leasing units at their respective properties to tenants that receive federal rent subsidies; and WHEREAS, the Parties desire to amend the Declaration by deleting paragraph four (4), as provided in the Amendment attached as Exhibit "A;" and WHEREAS, the City Commission finds that the Amendment is in the best interest of the public. NOW, THEREFORE, BE IT RESOLVED BY THE CITY COMMISSION OF THE CITY OF AVENTURA, FLORIDA, AS FOLLOWS: Section 1. Recitals Adopted. That the foregoing "WHEREAS" clauses are ratified and confirmed as being true and correct and are made a specific part of this Resolution. Section 2. Approval of the Amendment. That the Amendment to the Declaration, in substantially the form attached as Exhibit A, is hereby approved. Section 3. Implementation. That the City Manager or designee is authorized to take any action necessary to implement the Agreement and the purposes of this Resolution. City of Aventura Resolution No. 2022-58 Section 4. Effective Date. This Resolution shall be effective immediately upon adoption. The foregoing Resolution was offered by Commissioner Narotsky, who moved its adoption. The motion was seconded by Commissioner Joel, and upon being put to a vote, the vote was as follows: Commissioner Rachel S. Friedland Absent Commissioner Billy Joel Yes Commissioner Dr. Linda Marks Yes Commissioner Marc Narotsky Yes Commissioner Robert Shelley Absent Vice Mayor Denise Landman Yes Mayor Enid Weisman Yes PASSED AND ADOPTED this 13th day of September, 2022. ENID WEISMAN, MAYOR ATTEST: ELLISA L. HORVAT , IVIMC CITY CLERK APPROVED AS TO LEGAL SUFFICIENCY: ! /-# 41 '� CITY ATTORNEY This Resolution was filed in the Office of the City Clerk this 13th day of September, 2022. CITY CLERK Page 2 of 2 This Instrument was prepared by, and when recorded should be returned to: Robert Cheng, Esq. Shutts & Bowen LLP 200 South Biscayne Boulevard Suite 4100 Miami, Florida 33131 AMENDMENT TO DECLARATION OF RESTRICTIONS This Amendment to Declaration of Restrictions (this "Amendment") is entered into effective as of , 2022 (the "Effective Date"), between Imperial Club L.P., a Florida limited partnership ("Imperial Owner"), and BRE ROOK SH Sterling Aventura, LLC, a Delaware limited liability company ("Sterling Owner," and together with Imperial Owner, the "Parties"), and amends that certain Declaration of Restrictions dated as of November 16, 1990, recorded on January 23, 1991, in Official Records Book 14867, Page 1252 of the Public Records of Miami Dade County (the "Declaration"). RECITALS WHEREAS, Imperial Owner owns a parcel of real estate with a street address of 2751 N.E. 183rd Street, Aventura, Florida, that is improved with a fourteen story, a senior's living facility known as The Imperial Club ("The Imperial Club"); WHEREAS, Sterling Owner owns a parcel of real estate with a street address of 2777 N.E. 183rd Street, Aventura, Florida, that is improved with an eight story, an assisted living facility known as The Sterling ("The Sterling"); WHEREAS, in connection with obtaining certain development approvals from Miami- Dade County (prior to incorporation of the City of Aventura ("City")) with respect to the development of The Imperial Club and The Sterling, the predecessors in title of such properties executed the Declaration; WHEREAS, The Imperial Club and The Sterling comprise the property subject to the Declaration, as legally described in Exhibit A to the Declaration; WHEREAS, paragraph four (4) of the Declaration prohibits the owner of either the Imperial Club or The Sterling from leasing units at their respective properties to tenants that receive federal rent subsidies; WHEREAS, the Parties desire to delete paragraph four (4) from the Declaration; WHEREAS, while the terms of the Declaration require that any amendment be approved by the"Zoning Appeals Board or the Board of County Commissioners,whichever has jurisdiction, after public hearing", the Parties and the City recognize that because the property subject to the MIADOCS 24825871 1 Declaration is now within the jurisdiction of the City, particularly with respect to land use and zoning matters, the City possesses the authority to approve an amendment to the Declaration subject to a public hearing before its governing body; and WHEREAS, the Parties and the City desire to delete paragraph four (4) from the Declaration, and to leave the remainder of the Declaration unmodified. NOW THEREFORE, for and in consideration of the mutual covenants, conditions and undertakings contained herein, and other good and valuable consideration, each to the other provided,the receipt, adequacy and sufficiency of which is hereby acknowledged,the Parties agree as follows: Section 1. Deletion of Paragraph 4 . The Parties agree to delete paragraph four(4) of the Declaration in its entirety from the Declaration. The remainder of the Declaration shall remain unmodified by this Agreement. Section 2. Recording. Any Party is authorized to record this Amendment in the Public Records of Miami Dade County. [Signatures appear on the following pages] 2 MIADOCS 24825871 1 Executed as of the date first set forth above. WITNESSES: STERLING OWNER: BRE ROOK SH Sterling Aventura, LLC, a Delaware limited liability company, By: Print Name: Name: Title: Print Name: STATE OF FLORIDA ) ss: COUNTY OF ) The foregoing instrument was acknowledged before me this of 2022, by means of physical presence or online notarization by , as of BRE ROOK SH Sterling Aventura, LLC, a Delaware limited liability company, on behalf of the corporation and partnership. He/She (_) is personally known to me or (� has produced a driver's license as identification. NOTARY PUBLIC, State of Print Name: My Commission expires: Serial No.: [Signatures Continue on Following Page] Signature page to Amendment to Declaration MIADOCS 24825871 1 Executed as of the date first set forth above. WITNESSES: IMPERIAL CLUB OWNER: IMPERIAL CLUB L.P., a Florida limited partnership By: First Baptist Housing of Bridgeport, Inc., a Connecticut not-for-profit corporation Print Name: By: Print Name: Name: Title: STATE OF FLORIDA ) ss: COUNTY OF ) The foregoing instrument was acknowledged before me this of 2022, by means of physical presence or online notarization by , as of First Baptist Housing of Bridgeport, Inc., a Connecticut not-for- profit corporation, the general partner of Imperial Club L.P., a Florida limited partnership, on behalf of the corporation and the partnership. He(j is personally known to me or(_)has produced a driver's license as identification. NOTARY PUBLIC, State of Print Name: My Commission expires: Serial No.: Signature page to Amendment to Declaration MIADOCS 24825871 1 ACKNOWLEDGMENT BY THE CITY OF AVENTURA The City of Aventura ("City") acknowledges that the foregoing Amendment was validly approved by the City Commission after a public hearing, and has the effect of deleting paragraph four (4) from the Declaration of Restrictions recorded on January 23, 1991, in Official Records Book 14867, Page 1252 of the Public Records of Miami Dade County. WITNESS my hand and official seal in the county and state named above this day of , 2022. Approved: By: Title: Approved as to Legal Form and Correctness: By: Title: City Attorney Signature page to Amendment to Declaration MIADOCS 24825871 1 ATTACHMENT 2 ahufts August 4, 2022 VIA E-MAIL Keven Klopp Development Services Director, City of Aventura kloppkgcityofaventura.com Re: Imperial Club—Discrimination in Housing on the Basis of Source of Income Dear Keven, We represent Imperial Club SLP,LLC ("Purchaser'),whose sole member is Darren Smith, President of Smith & Henzy Affordable Group. Purchaser is under contract to purchase from Imperial Club, L.P. the property known as the Imperial Club, located at 2751 NE 183rd Street, Aventura, Florida, which offers independent and assisted living options for seniors within the City of Aventura ("Ci1y"). Upon closing, Purchaser intends to conduct an approximately $7,760,000 rehabilitation of the Imperial Club and operate it as an affordable seniors independent living facility. Purchaser's intended financing sources include the Low-Income Housing Tax Credit and Multifamily Mortgage Revenue Bond programs administered by the Florida Housing Finance Corporation, as well as the Project-Based Voucher Program administered by Miami-Dade County ("County") Public Housing and Community Development. It has come to our attention that there is a restriction contained in a recorded Declaration of Restrictions (the "Declaration," a copy of which is attached hereto as Exhibit A) that has the effect of discriminating against prospective tenants of the Imperial Club (and the neighboring senior living facility, The Sterling Aventura) on the basis of their source of income. Specifically, paragraph 4 of the Declaration (the "Subject Restriction") states: "No prospective resident of the (1) housing for elderly, (2) adult congregate living facility, or(3)nursing home who shall receive federal subsidies for housing assistance will be permitted to occupy any unit." For the reasons set forth in this letter, and the letter attached hereto as Exhibit B from Miami-Dade County's Commission on Human Rights' Director, Erin New, we respectfully request that the City include as an agenda item before the appropriate City board or council an approval of an amendment to the Declaration deleting the Subject Restriction,with a favorable recommendation from Staff. Laws and private restrictions that permit discrimination in the housing market based on source of income have come under attack nationally as "a form of modern-day redlining." (See, for example, An Illusion of Choice: How Source of Income Discrimination and Voucher Policies Perpetuate Housing Inequality, Februar0). For this reason, Miami-Dade County expressly outlawed this practice by enacting a Human Rights Ordinance, making it unlawful to MIADOCS 24665025 2 Page 2 of 2 discriminate against any person seeking housing in the County on the basis of their source of income. See Chapter 11A, Miami-Dade County Code of Ordinances. "Source of income" is defined to mean"the lawful, verifiable income paid directly to a tenant or paid to a representative of a tenant, including, but not limited to, Section 8 Housing Choice Vouchers..." (§I IA-2). As confirmed in the attached letter from the Director of the County's Commission on Human Rights, the Ordinance "is applicable in both the incorporated and unincorporated areas of Miami- Dade County,Florida." (§I IA-50). To be clear, the City was not involved in the imposition of the Subject Restriction. The Declaration was executed in connection with certain local development approvals obtained from Miami-Dade County (prior to incorporation of the City) by a predecessor owner of the property upon which the Imperial Club and The Sterling Aventura now sit. The terms of the Declaration require that any amendment be approved by the "Zoning Appeals Board or the Board of County Commissioners, whichever has jurisdiction, after public hearing." As you have recognized, however,because the property subject to the Declaration is now within the jurisdiction of the City, the City steps into the shoes of the County and possesses authority to approve an amendment to the Declaration. Finally, and critically, the removal of the Subject Restriction will unlock a capital improvement program in the approximate amount of $7,760,000, designed to enhance the look and feel of the Imperial Club for the benefit of its residents, neighbors, and the City as a whole. Please do not hesitate to contact me should you wish to discuss this further. Sincerely, SHUTTS & BOWEN LLP /s/Mark E. Grafton. Esq. Encl. Cc: Darren Smith (DSmithgSmithhenzom) Robert Cheng, Esq. (RChenggshutts.com) James Carmichael (James.Carmichael(c�r�,ST-Residential.com) Mickey Marrero, Esq. (MMarrero(c�r�,brzoninglaw.com) MIADOCS 24665025 2 Exhib it A c14rY�S.I'IYI ulaa• S.t�� t�a�ll,,r��?,tw•-- n ue,a.nwr cawr 1991 A. 23 AH & 52 91R022535 OrF AEC. 1486741252 DECLARATION OF RESTRICTIONS KNOW ALL MEN BY THESE PRESENTS, that the undersigned, being the owners, or having some right, title or interest in the following described property (the "Property"), lying, being and situated in Dade County, Florida to wit: SEE ATTACHED EXHIBIT "A" In order to assure Dade County, Florida, that the representations made to it by the undersigned during consideration of Public Hearing Application Number 89-251 will be abided by, voluntarily makes the following Declaration of Restrictions covering and running with the Property: (1) Specification of Site Plans. The said property shall be developed substantially in accordance with the spirit and intent of the plans previously submitted, prepared by Shaymon 6 Salk Company, Architects, entitled "Imperial Club", consisting of 7 pages of site plans, floor plans and elevation drawings, last revised June 11, 1990, and also a landscape plan prepared by O'Leary Design Assoc. consisting of 1 page and dated 1-4-90, said plans being on file with the Dade County Building and Zoning Department, and by reference made a part of this Declaration. (2) Limitations on Uses. The use of the Property shall be restricted to (1) housing for the elderly; (2) adult congregate living facility; and (3) nursing home. For purposes of this Declaration "housing for the elderly" shall be defined as Prepared By: Eileen Ball Mehta Fine Jacobson Schwartz Nash Block England 100 S.E. 2nd Street Miami, Florida 33131 J K !! T ■iGarHOTOGp�rM M a FIVE[oi C„,wT�MNrrtT.�e73 uru,cre.�uu�'x N��w_ri,�y.yy}�_y�„_ °FACCF. 14867n i 253 . housing which is occupied exclusively by persons 62 years of age or older. (3) Limitations on Beds. No more than one bed shall be permitted in each bedroom. This limitation shall not apply to individual units occupied by husband and wife or by two related persons by blood, marriage and consenguity, but in no event will more than two individuals occupy any unit. (4) Eligibility. No prospective resident of the (1) housing for the elderly, (2) adult congregate living facility, or (3) nursing home who shall receive federal subsidies for housing assistance will be permitted to occupy any unit. (5) Notice. Owners hereby agree to the following: 5. 1 At the time of entering into leases with residents and hiring of employees the Owners will notify them that the primary entrance to the Property will be Northeast 186 Street and not Northeast 183 Street (the "Entrance Information") . 5.2 The Entrance Information will be continuously disseminated through inter-company memos, fliers, brochures and the like. 5.3 Place signs throughout the Property reminding residents, employees, guests, vendors and construction traffic that access to the Property shall be as set forth in the Entrance Information. The signs shall comply with the applicable provisions of the Code of Metropolitan Dade County, Florida and shall direct all residents, employees, guests, vendors, and construction traffic to access the property at N.E. 186th Street. -2- b n xar rie ;rW T RMY THAT IKII, NIGROPSIQTaGRIIq IS• [��r REf: 1486N 1254 5.4 During all phases of construction, all construction vehicles will be directed to enter and exit the subject Property from N.E. 186th Street only. 5.5 Owners and/or Owners, representative agree to meet with members of the Admirals Port Condominium Association, Inc. and Commodore Plaza Condominium Association, Inc. (the "Associations" to discuss issues related to the Property including but not limited to access to the Property. 5.6 Owners existing security patrol will include in his patrol, the Century Building at 2780 N.E. 183rd Street and Owner will provide prior to the issuance of a building permit for the installation of two security cameras in the Commodore Plaza Security System. 5.7 The agreements contained in this paragraph 5 of the Declaration of Restrictions are made for the benefit of Admirals Port Condominium Association, Inc. and Commodore Plaza Condominium Association, Inc. and shall be enforceable by the Associations by binding arbitration or by judicial proceedings. Enforcement of the provisions of this paragraph 5 shall not be the responsibility of Dade County. In the event that either N.E. 183rd and/or N.E. 186 Street is dedicated to Dade County, this provision may be enforced by Dade County. (6) Inspections. The Owners agree that any official inspector of the County Building and Zoning Department, or its agents duly authorized, may have the privilege at any time during normal working hours of entering and investigating the use of the -3- h _ i$4if f d i r r>ii 7 � r �f ` RKYi.e.. rvn a.u�.a.anr aeu.r '148011 Z55 Property to determine whether or not the requirements of the building and zoning regulations and the conditions in this Declaration are being complied with. The Owners further agree that the Director of the Building and Zoning Department may, from time to time, make inquiry regarding the occupancy of the Property, and the Owners shall furnish documents reflecting the number of residents within the facility in response to such inquiry. Within 12 months following receipt of documentation indicating that a 75% level of occupancy has been achieved, and again within 12 months following receipt of documentation indicating that a 90% level of occupancy has been achieved, the Director of the Building and Zoning Department may, in his discretion, cause a reinspection of the Property to determine whether the parking provided on the Property is adequate to serve the parking needs of the Facility. Should the Director of the Building and zoning Department determine that the parking is inadequate, the Director and the Owners shall attempt to reach an agreement whereby the Owners shall either provide additional parking or shall reduce the number of residents to a number which will not cause an over-utilization of existing parking facilities. In the absence of such an agreement between the Director and the Owners, the Director may file an application with the Zoning Appeals Board seeking a modification of the non-use variance of parking requirements and requiring the Owners to provide additional parking for the Property or reduce the number of residents. In the event that the Director files such -a- Tr a't r'�4 y � do t.f � ,a ;�y f iE }'� F"e di r •"�' - ', 1 tlll6T QII TI TfM.iT ItIll, ■KAarnur wit�rnu• .,..,...a.. ...., OFF REC. 1486741256 ' an application, the Owners agree that they shall not cause the number of residents to be increased during the pendency of the application. This provision shall not be deemed to preclude the Director from utilizing all the powers prescribed in Chapter 33 of the Code. (7) Term of Declaration. The provisions of this instrument shall become effective upon their recordation in the public records of Dade County, Florida, and shall continue in effect for a period of thirty (30) years after the date of such recordation, after which time they shall be extended automa- tically for successive periods of ten (10) years, each, unless an instrument in writing signed by a majority of the then owners of the Property and Dade County has been recorded agreeing to change or release the covenants in whole, or in part. (9) Modification. The provisions of this instrument may be amended, added to, derogated, deleted, modified, or changed from time to time by a recorded instrument executed by the then owner or a majority of the owners of all of the Property, provided that such modification, amendment, or release is also approved by the Zoning Appeals Board or the Board of County Commissioners, whichever has jurisdiction, after public hearing. Should this Declaration be so modified, amended, or released, the Director of Metropolitan Dade County Building and Zoning Department, or his successor, shall forthwith execute a -5- 41� •r , 1 T MKiT IHIN •KMa/,wi W+,.rn u v�y'�rur'^wNiT aeCr —� c . Ur R`f. REC. 1486R I T written instrument effectuating and acknowledging such modification, amendment, or release. (9) Enforcement. Enforcement shall be by action at law or in equity against any parties or persons violating or attempting to violate any covenants, either to restrain violation or to recover damages. The prevailing party in the action or suit shall be entitled to recover, in addition to costs and disbursements allowed by law, such sum as the court may adjudge to be reasonable for the services of his attorney. (10) Presumption of Compliance. When construction has occurred on the Property or on any portion of the Property pursuant to a lawful permit issued by Dade County, and inspec- tions made and approval of occupancy granted by Dade County, then such construction, inspections, and approval shall create a presumption that the buildings or structures thus constructed comply with the intent and spirit of this Declaration. (11) Authorization to Withhold Permits and Inspections. In the event payments and or improvements are not made as promised, in addition to any other remedies available the Dade County Building and Zoning Department is hereby authorized to withhold any further permits and refuse any inspections or grant any approvals, until such time this Declaration is complied with. (12) Covenant Running With Land. These restrictions during their lifetime shall be for the benefit of, and limitation upon, all present and future owners of the Property and for the public welfare. This Declaration on the part of the owner shall -6- . V` xvjity�rpS f n u NY9 �5 , inia W,CM YIGROFlIOTOGR�NIK IIC►IIC�tKTlm,f °AEC."• 1486T41258 . constitute a covenant running with the land and may be recorded in the public records of Dade County, Florida and shall remain in full force and effect and be binding upon the undersigned, and their heirs, successors and assigns until such time as the same is modified and or released. Any references in this Declaration to the undersigned shall include the undersigned's heirs, successors and assigns, as applicable. (13) Severability. Invalidation of any of these covenants, by judgment or court, in no way shall affect any of the other provisions of this instrument, which shall remain in full force and effect. -7- r � r � M1 •� 7, .11 �. �+r� �� •f°1i '�%�?4�•k;��Yr�n�N'Riio:;�1htu,n•�ag7�R����, ��C,`F L'1'�'O1r.�. is �e 'sv 7 � •:S'�i' i a iuiairc.iFnoniarcciunncxer�coucnaws °IACCF'. 1486T?C 1259 Signed, sealed, executed and acknowledged on this 16th day of November , 1990, at Chicago , Illinois Witnesses: PORT NATA ASSOCIATES, LIME D PART R IP By: / enera ner a-- STATE OF ILLINOIS ) ss COUNTY OF COOK ) I, an officer authorized to take acknowledgments, according to the laws of the State of Illinoisduly qualified and acting, do hereby certify that on this date appeared before me Rudolph Tessler a general partner in Port Sonata Associates, Limited Partnership to me personally known, who acknowledged the foregoing instrument for the purposes therein contained, and had acknowledged that he was authorized to execute said instrument as the act and deed of the partnership. IN WITNESS WHEREOF, I have hereunto set my hand and seal at this le id day of 1990. OFFICIAL SEAL SAIORA 1. BAII ^ NOTARY PUBLIC STATE OF IWNOIS U/t/ICY Eli— ��L MT COMMISSION EIP. MAY 31.1"1 Notary Public My Commission Expires: 124RL0151E sYi a{. •:�crA�ryw,,`ix�'wy� � � Lf Y F � �� i r r�3. 'S,`'� ���7��i7rt r ;,J�I+,wit�r'�3'.��,{{�'a ^��,-'�� a���,t�-•4�•+� ��'"�,{s�� - �*' b, IIAM[IfY.1(AOM07CG4MIC[lPRWIICTIpN} ' I n nur.a.axr arwt p«: 1486T?�,1260 EXHIBIT "A" Tract "A" of Port William subdivision, according to the Plat thereof, as recorded in Plat Book 127, at Page 46 of the Public Records of Dade County, Florida. 124RL0151E -9- )c�o fi�yr'�,f^�1 'Sl�' `,-�+R r '•��'•4.,*t f •,p ��^••izwur M1...OT_i K.�—� ri-uWarrr• r" n nu•.wcwr cvu.r • NEC. 1486741 Z61 JOINDER BY MORTGAGES The undersigned, TRUSTBANR SAVINGS FSB, a federally- chartered savings bank, as successor in interest to Dominion Federal Savings and Loan Association, Mortgagee, under those certain two mortgages from Port William Limited Partnership, each dated March 20, 1985 and each recorded on March 28, 1985, one in Official Records Book 12458 at Page 3322 of the Public Records of Dade County, Florida and the other in Official Records Book 12460 at Page 14 of the Public Records of Dade County, as modified and further consolidated by that certain Consolidation, Restatement and Assumption of First and Second Mortgages dated May 16, 1988 between Port William Limited Partnership, Port Sonata Associates Limited Partnership and Dominion Federal Savings and Loan Association recorded on May 18, 1989 in Official Records Book 13684 at Page 25 of the Public Records of Dade County, Florida, securing a consolidated indebtedness in the amount of $15,567,682.81 covering the property described in the foregoing agreement, does hereby acknowledge that the terms of the agreement are and shall be binding upon the undersigned and its successors in title. -10- , .Ticwfih. `.7�1�''fti n Elk v � eri/YTruT rlcparndrwe�rnn• caw. IUN[Irt■lrRanlmOcaA Enic R[aRcnDcrLaNYGFr . r .REC 14867?E 1262 ' REC. IN WITNESS WHEREOF, these presents have been executed this 21st day of November 1990. TRUSTBANK SAV_UIQS FSB By: Its: mTCPA71, T)T'VT,T11 Signed and Sealed in the .PreseNce of: wit S Witness STATE OF VTRCTN1TA ) Ss CnijVTr' nF r'r,IRFA`C ) The foregoing instrument was acknowledged before me this 21st day of November , 1990, by 1*ICl'.11T1, OT:VLIM Vice President of Trustbank Savings FSB, a federally-chartered savings bank, on behalf of the bank. �w•`My Commission Expires: t,,•�.Y 11 ••• gyp': -.V 91 ) he Q CL Z r�rz,�!�J Notary Public �.k?y "rT2r`T1 ANVIF.T T)MIN S' ........... 3. .. RECORDED IN 0")VAL"CC)RM loos OF DADE COUNTY,FLORIDA. RECORD VERIFIED _ Clerk of Circuit&County < -l a Courts SC Exhib it B Human Resources MIAMI-DADE Human Rights and Fair Employment Practices 111 NW 1It Street•21It FL Miami, FL 33128 miamidade.gov T 305-375-2784 F 305-375-2114 August 3, 2022 Sent Via Email: mgrafton(abshutts.com Mark E. Grafton, Esq. Shutts & Bowen, LLP 200 South Biscayne Blvd., Suite 4100 Miami, FL 33131 Re: Imperial Club Declaration of Restrictions Dear Mr. Grafton: I am in receipt of your letter dated August 2, 2022, in which you request that the Miami- Dade County Commission on Human Rights ("Commission") issue a statement about certain information contained in the Imperial Club's Declaration of Restrictions ("Declaration"). Specifically, the Declaration states, in part, "No prospective resident ... who shall receive federal subsidies for housing assistance will be permitted to occupy any unit." As you are aware, the Commission is responsible for enforcement of Chapter 11A of the Miami-Dade County Code, as amended, ("Chapter 11K), the County's Human Rights Ordinance, which is applicable in both unincorporated and incorporated Miami-Dade County. Chapter 11A makes it unlawful for any person, owner, financial institution, real estate broker, real estate agent or any representative of the above to discriminate against a prospective buyer, renter, or lessee because of race, color, religion, ancestry, national origin, age, sex, pregnancy, disability, marital status, familial status, gender identity, gender expression, sexual orientation, source of income, or actual or perceived status as a victim of domestic violence, dating violence or stalking. Chapter 11A defines a person as "one (1) or more natural persons, individuals, employees, employers, employment agencies, owners, businesses, government, government agencies, government departments, unions, joint apprenticeship committees, firms, associations, joint ventures, partnerships, estates, trusts, trustees, trustees in bankruptcy, legal representative, mutual companies, joint-stock companies, receivers, syndicates, fiduciaries, corporations, unincorporated organizations, and all other groups or combinations." Chapter 11A further defines "source of income" as "the lawful, verifiable income paid directly to a tenant or paid to a representative of a tenant, including, but not limited to Section 8 Housing Choice Vouchers, Supplemental Security Income, Social Security, pensions and other retirement benefits." As such, it is our determination that if the provision of the Declaration described herein were enforced to prohibit certain tenants from renting in a development based on their source of income, then any person aggrieved by this unlawful housing practice, or our office, could initiate a complaint to seek enforcement of Chapter 11A against the person who violated the law either by filing a complaint with the Commission or filing a private cause of action. Please contact me at (305) 375-2784, or via e-mail at erin.new@miamidade.gov, should you have any questions regarding this matter. Sincerely, Erin A. New, Division Director Commission on Human Rights, Human Rights & Fair Employment Human Resources Department