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DOMINGO:Mr. Rodrigues, you know, your client immediately after the approval of <br />the permit could have immediately responded to some of the conditions of approval. Why did he <br />not do so? <br />RODRIGUES:The answer is, Ill give you a direct answer, Mr. Domingo, he did for a <br />time; and then I noticed the same thing. Okay? Now maybe thats disclosing confidences of my <br />client but weve had many discussions about this. And it would be more proper for him to <br />rd <br />explain the why but not the what, okay? The what was when I wrote that letter on November 3 <br />th <br />and when the violations occurred prior to October 20; and as Commissioner Rho stated there <br />may have been violations before then. Okay? They were each corrected in serial fashion when <br />they happened, with or without government prompting. Now why was that? There are many <br />reasons, some of which may, and some of which may not, be acceptable to the Commission. <br />Thats for the Commission to hear, thats for my client to state. But Im following the <br />Commissions reasoning on this and Im sure that my client will get a full appreciation of what <br />went on here today. Im not sure if I answered your questions specifically enough. <br />DOMINGO:Thats okay, I understand what youre trying to tell me. <br />GRAHAM:Go head, Mr. Domingo, finish up, please. <br />DOMINGO:Id just like to ask the Department if they at any time had received any <br />responses to the conditions of approval with regards to submitting plans and indicating other <br />measures? <br />GRAHAM:Jeff? <br />DARROW:Unfortunately we did not, and that was the reason for the violation notices <br />going out. We did not receive submittal for plan approval within the one year requested as well <br />as the site plan requested. <br />DOMINGO:Nowinyourrequestforacontinuance,areyoudisputingthefine,thecivil <br />fine that has been levied upon your client? Is he disputing this? <br />RODRIGUES:I would advise my client to dispute them. Ill tell you why, the short <br />answer,okay?Ithinkthattheproperprocedureshouldhavebeenthatwereceivesomekindof <br />th <br />communication as to the October 20 <br /> violations, which we did; and it stated in there what the <br />sanctions could be if and when corrections were not taken. There was a response to that <br />rd <br />prepared by me on November 3, okay? To me things went into never never land when we <br />didnt get a response from the County. So -. <br />DOMINGO:WhatwasyourresponsetothePlanningDepartment? <br />RODRIGUES:Explanationforthedelay,Idonthavetheletterinfrontofme.Butmy <br />recollection is explanation for the delay, and removal of things from the high ground that was <br />visible.Ibelievethatsessentiallywhatitwas. <br />DOMINGO:Onlythat? <br />13EXHIBIT C <br /> <br />