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2026-06-19 Motion to Dismiss (PL-BOA-2026-000133 ROHR).pdf
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2026-06-19 Motion to Dismiss (PL-BOA-2026-000133 ROHR).pdf
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6/25/2026 11:12:59 AM
Creation date
6/25/2026 11:12:04 AM
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Plan Doc Template
Document Date
6/19/2026
Permit Number
PL-BOA-2026-000133
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2026-06-19 Motion to Dismiss (PL-BOA-2026-000133 ROHR).pdf
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B. All Activity Authorized by the SMA Minor Permit Has Concluded Leaving <br />No Redressable Live Controversy <br />The SMA Minor Permit authorized a limited, short-term video shoot consisting of a brief <br />preparation period and one day of filming to take place primarily on private property with <br />limited activity on a public beach which remained accessible to the public at all times. Filming <br />occurred on May 22" d and has been completed with no lingering effects. Neither Appellant nor <br />any other member of the public was denied access to any area, publicly accessible or otherwise, <br />as a result of the issuance of the SMA Minor Permit. No structures were built and no permanent <br />lighting or installations were used. The area was returned to its original condition upon <br />completion of the activity. The Planning Department has received no complaints about the <br />condition of the private property or the public beach following the filming activity. The <br />Landowner and the Filming Company have no current plans to return to conduct additional <br />filming activities or to apply for additional SMA approvals. Should either party ever decide to <br />conduct additional filming on the property or elsewhere on the island, all appropriate permits and <br />approvals would be applied for at that time. Any future permits are beyond the scope of this <br />appeal. <br />Revocation of the SMA Minor Permit would not only be baseless but would have no <br />effect because no ongoing activity or injury exists to be prevented or remedied. Appellant has <br />alleged no facts indicating any injury that is redressable by this Board. <br />IV. CONCLUSION <br />Appellant has failed to allege any facts, specific or otherwise, to support her statement <br />that "her interests have been injured" by the Director's issuance of the SMA Minor Permit. <br />Having failed to establish an injury to an interest that is directly and immediately affected and <br />n <br />
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