HomeMy WebLinkAboutDeclaration: Lillig, Laurence M Jr
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STATE OF INDIANA
) IN THE HAMILTON SUPERIOR COURT
)SS: #3
) CAUSE NO. 29D03-0005-CP-334
COUNTY OF HAMILTON
STATE OF INDIANA ex reI )
KINGSWOOD HOMEOWNERS ASSOCIATION )
and KINGS WOOD HOMEOWNERS ASSOCIATION, )
)
Plaintiffs, )
)
vs. )
)
STEVEN ENGELKING, Director of the )
City of Carmel Department of Community Services, )
CITY OF CARMEL AND CLAY TOWNSHIP )
BOARD OF ZONING APPEALS, consisting of )
CHARLES WEINKAUF, PAT RICE, )
LEO DIERCKMAN, MICHAEL A. MOHR, and )
EARLENE PLA VCHAK, CITY OF CARMEL, and )
MARTIN MARIETTA MATERIALS, and )
HUGHEY, INC. d/b/a Carmel Concrete Products, Co., )
)
Defendants. )
VERIFIED DECLARATION
OF LAURENCE M. LILLIG, JR.
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Laurence M. Lillig, Jr., makes the following declaration under the penalties for perjury:
1. I am the planning and zoning administrator for the City of Carmel, a position I have
held since August 23, 1999. I make the statements in this declaration on my personal knowledge or
on the business records of the City of Carmel. I am competent to testify as to the facts stated in this
declaration and would so testify if called as a witness.
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2. My responsibilities as planning and zoning administrator include reviewing
applications for development plans, subdivision plats, and variances from the zoning and subdivision
control ordinances of the City of Carmel and Clay Township. I am personally familiar with Martin
gravel mining operations on property located north of East 106th Street between
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Gray Ro cIH I Dell Parkway in Cannel. These mining operations are outside of the corporate
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boundaries of the City of Carmel.
3. I also am personally familiar with the real estate owned by the Mueller
conservatorship, located both north and south of East 106111 Street between Gray Road and Hazel Dell
Parkway, also outside the corporate boundaries of the City of Carmel. No one has ever submitted
a plat for approval to develop the Mueller property as a residential subdivision, nor has such a plat
ever been approved by the City of Carmel or Clay Township. The Mueller property has never been
subdivided into residential lots, or otherwise planned for use as a residential area.
4. The Mueller property north of 106th Street abuts the Kingswood subdivision on the
south and on a very small comer on the east. The Mueller property north of 106111 Street contains one
residence located on the east side of the property on Hazel Dell Parkway. However, no portion of
the Mueller property is used for residential purposes within a quarter-mile square area in which there
are at least eight residences.
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5. The Mueller property south of 106th Street is not contiguous to the City of Carmel.
No portion of the Mueller property south of 106th Street is within a quarter-mile square area in
which there are at least eight residences.
I declare under the penalties for perjury that the foregoing statements are true.
Executed on March.f, 2001
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La ~ ill' , Jr. I
p . . g ~dministrator
City of Carmel
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CERTIFICATE OF SERVICE
The undersigned hereby certifies that a copy of the foregoing document has been served this
_ day of March, 2001, by depositing a copy of the same in the United States mail, first class
postage prepaid and properly addressed to the following counsel of record:
William E. Wendling Jr.
Todd Ruetz
CAMPBELL KYLE PROFFITT
10 East Carmel Drive, Suite 400
Carmel, Indiana 46032
Douglas C. Haney, City Attorney
CITY OF CARMEL
One Civic Square
Carmel, Indiana 46032
John R. Molitor
MOLITOR GRISHAM & HESTER
11711 North Meridian Street, Suite 200
Carmel, Indiana 46032
JayP. Kennedy
KROGER GARDIS & REGAS, LLP
111 Monument Circle, Suite 900
P.O. Box 44941
Indianapolis, Indiana 462044-0941
Jan M. Carroll
INDS02 JMe 366860vl
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