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2026-02-05 Kellberg's Pre-Hearing Brief (PL-BOA-205-000124)
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2026-02-05 Kellberg's Pre-Hearing Brief (PL-BOA-205-000124)
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stating that the Director would do nothing to bring the subdivision into compliance. Id. at 521. In <br /> 2010, again in circuit court on second appeal, Kellberg filed another Motion for Partial Summary <br /> Judgment seeking an injunction requiring the Planning Department to alter the subdivision and to <br /> enjoin the County from "allowing the further sale, transfer of ownership, or development and <br /> improvements" of the lots until compliance is demonstrated. Id. at 522. In 2015, following the <br /> Court's ruling that Kellberg must join the lot owners if feasible, Kellberg filed his First Amended <br /> Complaint joining the Pruglo Lot Owners and asserting the same claims without seeking damages. <br /> Summary Disposition Order,Kellberg v. Kern, CAAP-19-0000833 (hereinafter,"SDO"),Dkt. 144 <br /> at 3 (App. 2024) ("He sought a declaration that the subdivision approval was invalid; an injunction <br /> against further development of the subdivision; and an injunction against Lot Owners trespassing <br /> on his property."). From start to finish, all of Kellberg's previous pleadings,motions, and appeals <br /> argued one issue that the mistaken approval voided the Subdivision. <br /> While Kellberg still maintains that the Subdivision's erroneous approval should equate to <br /> invalidity, Kellberg recognizes that the courts have declined to extend such remedy due to <br /> mootness. Kellberg therefore does not now contest the finality of the Subdivision's approval nor <br /> does he seek an injunction requiring the Planning Department to revoke the Subdivision. Instead, <br /> Kellberg's Petition asks the Planning Director"to what extent Ch. 23 and 25 apply to the properties <br /> covered by [the Subdivision and] how the zoning, subdivision, and other development and <br /> construction related codes should treat these lots." Petition at 11. In other words, now that the <br /> Subdivision will not be undone, what exactly can the Pruglo Lot Owners do with their lots? <br /> Whereas the previous litigation was retrospective insofar as it focused on the approval's expo facto <br /> consequences on the Subdivision's validity, the instant issue is prospective because it turns to the <br /> future application of the County Code moving forward. Kellberg's Petition therefore presents a <br /> 11 <br />
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