HomeMy WebLinkAboutLetter #02 Anthony Jost
ANTHONY R. JOST
Direct Fax: (317) 955-7152
E-mail: tjost@rbelaw.com
March 15, 2021
VIA E-MAIL
Mr. Joe Shestak
Administrative Assistant
Carmel Plan Commission
One Civic Square
Carmel, Indiana 46032
jshestak@carmel.in.gov
Mr. Mark Gradison
Co-Founder Gradison Land Development,
Inc. and Gradison Design Build
6330 E. 75th Street, Suite 156
Indianapolis, Indiana 46250
mgradison@gradison.net
Mr. Adam Mears
Land Use & Project Facilitator
Gradison Design Build
6330 E. 75th Street, Suite 156
Indianapolis, Indiana 46250
amears@gradison.net
Mr. Joe Gradison
Co-Founder Gradison Land Development,
Inc. and Gradison Design Build
6330 E. 75th Street, Suite 156
Indianapolis, Indiana 46250
jgradison@gradison.net
Paul G. Reis, Esq.
Legal Counsel
Carmel Plan Commission
One Civic Square
Carmel Indiana 46032
preis@carmel.in.gov
Mr. Brett Huff
Associate
Kimley-Horn & Associates Inc.
250 East 96th Street, Suite 580
Indianapolis, Indiana 46240
brett.huff@kimley-horn.com
Mr. Jeffrey C. McDermott
President & CEO
The Great American Songbook
Foundation Inc.
1 Carter Green
Carmel, Indiana 46032
jmcdermott@thecenterpresents.org
Mr. John Bain
President/CEO
Old Town Design Group
1132 South Rangeline Road, Suite 200
Carmel, Indiana 46032
Re: Simon Asherwood Estate Primary Plat Application
Property Address 10110 Ditch Road, Carmel, IN 46032
Docket No. PZ-2021-00003 PP, PZ-2021-00008 SW, PZ-2021-00009 SW and
PZ-2021-00010 SW.
Effected Real Estate Described as Follows: Tax ID Parcels 17-l 3-09-00-00-
013.000, 17-13-09-00-00-014.000 and 17-I3-09-00-00-014.001
March 15, 2021
Page 2
Dear Carmel Plan Commission, Gradison Land Development Representatives and Interested Parties:
We are counsel for numerous homeowners that reside on properties abutting the Simon
Asherwood Real Estate located at 10110 Ditch Road, Carmel, Indiana 46032 (“Asherwood Estate”). We
are writing to object to any current proposed primary plat application, requests for waiver of design
standards, development plan or any future plan to redevelop the Asherwood Estate in a manner
inconsistent with the “Agreement Establishing Restrictive Covenants,” as amended in 1960, affecting a
240-acre parcel which includes the Asherwood Estate and the surrounding area (“Restrictive Covenants”).
On its face it is unclear whether the current proposed Primary Plat Application and Requests for
Design Standards Waivers for the Asherwood Estate as filed with the Plan Commission is in compliance
with the Restrictive Covenants. The Restrictive Covenants contain a requirement that each lot include a
front yard setback of at least 75 feet from the street or highway right-of-way line. The Plan Commission
should be aware that the developer, Gradison Land Development (“Gradison”), has notified affected
property owners who are subject to the Restrictive Covenants, including our clients, that they intend to
seek to vacate this 75-foot front setback provision, as stated on page 7 of the attached document Gradison
distributed to property owners affected by the Restrictive Covenants.
We do not agree to any variance given without an agreement from the affected property owners
that would be contrary to the Restrictive Covenants, including the 75-foot front setback requirement. We
request that the Plan Commission confirm Gradison’s intentions to comply with the Restrictive
Covenants, including the 75-foot front setback, demand that any approval of the Plat submission comply
with the Restrictive Covenants, and specify any requirements for subsequent review by the Plan
Commission to confirm Gradison’s full compliance.
Additionally, as the Plan Commission considers whether to approve Gradison’s request for a
Residential Access Standards Waiver, we request assurances that the proposed future second entrance via
Royalton Drive would be gated and accessible solely for emergency vehicles in the event the main
entrance on Ditch Road is blocked, and not permitted for use by service or construction vehicles or
Asherwood Estate residents and visitors. If Gradison is granted permission to privatize the roads within
the Asherwood Estate, the limitation on this second access point also seems appropriate and reasonable.
The Restrictive Covenants have remained the guidepost for development within the immediate
area and have influenced the surrounding neighborhoods and community. The Restrictive Covenants do
not permit amendments with less than unanimous approval of the current landowners within the 240-acre
area. Interest in maintaining their protections is not limited to certain individuals within the property
boundaries, but also includes the established nearby neighborhoods of Coppergate, Laurel Ridge, and
Laurelwood.
March 15, 2021
Page 3
Any attempt to change the Restrictive Covenants without unanimous approval of current owners,
or to develop the property in a manner inconsistent with the Restrictive Covenants, will be deemed an
illegal breach of the Restrictive Covenants and opposed. There are a number of individuals and
neighborhoods interested in providing financial and community support that would be required for a legal
challenge. However, we hope that will not be necessary and invite all interested parties to work together
toward a development of the Asherwood Estate that is acceptable to all concerned neighbors.
Our clients are open to discussing solutions that maintain the spirit and integrity of the Restrictive
Covenants while encouraging development of the Asherwood Estate. However, the Restrictive
Covenants must be adhered to in the process or amended by unanimous consent of the affected property
owners through proper legal means. If Gradison or the Carmel Plan Commission is interested in
discussing workable solutions, please do not hesitate to call or email the undersigned.
Sincerely,
RILEY BENNETT EGLOFF LLP
Anthony R. Jost
Asherwood Development -2/4/2021
Asherwood Development -PropertyBoundaries107 Acres
North
Asherwood Development -CovenantRestrictedAreaDitch Road
Deerfield
Summerlakes
Asherwood
Estate
Asherwood Development -PhaseISummerlakes Park Area
Asherwood Development -PhaseII20 Acres +/-
Deerfield
Asherwood Development -Approx.Lot Dimensions
Asherwood Development -Setback Example75’ Front Yard Setback Per Covenant
40’ Rear Yard Setback Per S-1 Zoning
•The developer seeks to vacate the covenant for the front yard set-back of 75’.
•The new front yard setback would be 40’ which is the S-1 standard in the underlying zoning.
•All lots in this proposed phase I primary plat application will be one acre or greater and
comply with all other requirements of the restrictive covenants.