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MESHBESH HR. SINGER & SPENCE. LTD. <br />Orono City Council <br />November 19, 1990 <br />Paqe Three_ _ _ __ <br />service is considered an expanded use, it is ? <br />similar economic hardship. If the current proposal is denied, the <br />existinq conditional use permit would remain in existence <br />boat sales, nautical shop), because there is no voluntary intent to <br />abandon such use. <br />we continue to be amenable to a fair and non-litigious resolu­ <br />tion of this matter; however, considerable time, effort and money <br />Save already Itln eioended to make this investment a success. If <br />thr-expinded- use is denied, the existing use should surely be <br />allowed. - — <br />In addition to the two arguments set forth above, alternative <br />factory relief. SBM has relied, in good faith, on ^ ^ , <br />use is^now withdrawn would likely subject the City to liability <br />under the vested rights doctrine. <br />Finallv. if the City continues to assert that the property can <br />ii<5e or benefit, the landowner must receive just compensation. <br />that restricina the use of 1960 Shoreline Drive to single <br />existing zoning regulations. <br />V. Los Angeles County, 482 U.S. 304 (1987). <br />AS always, SBM remains willing to discuss this matter to <br />arrive at a fair alternative solution. However, as set fo