701 pages, 144 mb of lawsuit. I have posted a link to the Yacht Club by Luxcom v. Village of Palmetto Bay. A very long read.

The full complaint finally went public today (Tuesday, 11/10/2020). The LUXCOM complaint was filed November 05, 2020, but it was not visible to the public until it went through 'redaction'. I now know why it took so long, the entire complaint is a total of 701 pages (144 MB). 

701 pages CLICK HERE to download and view the entire 701 pages.

  51 pages CLICK HERE to view the smaller 51 page document, the complaint, minus the exhibits.

The tone is set in the Introduction, page 1:

This is an action in which Luxcom seeks to recover millions of dollars in damages from the Village based on its unlawful, inequitable, discriminatory, deceptive and bad faith actions and the Village ' s material misrepresentations by virtue of its silence and omissions/failure to disclose critically important information to Luxcom relating to its purchase of a large tract of undeveloped land in excess of 70 acres in Palmetto Bay for $33 million dollars and Luxcom's repeated attempts to develop the property which have been continuously thwarted by the Village. 

YACHT CLUB BY LUXCOM, LLC VS VILLAGE OF PALMETTO BAY, FLORIDA, 2020-023918-CA-01, filed its latest lawsuit, the formal Bert J. Harris claim, on Thursday, November 5, 2020.

The complaint does make for colorful reading. Beginning numbered paragraph 10, (page 4 of 51, or 701) Plaintiff describes the proceedings  as having been conducted in a manner …

(10.) … that rivaled the likes of the Star Chamber courts of England's King Henry VIII. During these sham hearings, the Village failed to comply with and properly apply its own Code and the proceedings discriminated against Luxcom and violated its due process rights - all in furtherance of the Village's carrying out its above described plan of severely limiting development on Luxcom's property. The outcome of these hearings (and enacting the ordinances) was pre-detennined by the Village whose Council did not act as a fair and impartial tribunal but, rather, as an advocate of its own self-sponsored ordinances.

11. The Village Council's lack of fairness and impartiality was on full display at these public hearings. The lack of impartiality was thrown into the spotlight when both Vice Mayor John Dubois (who served as the Village' s sponsor for the ordinances) and Council Member Marsha Matson (who, amongst others, campaigned for her Council seat based on promises of limiting development on the property to no more than one unit per acre) -- both failed to recuse themselves from the voting. They both voted in favor of what was a fait accompli - enacting the ordinances.

Please take the time to review this entire complaint. I am unaware as to whether the Village has been served with this complaint. Palmetto Bay will have twenty (20) days to file and serve its response unless the time is extended, which I expect to be extended given the depth of the issues as well as the length.

As previously reported, this latest case is assigned to the Honorable Martin Zilber, Circuit Court Judge, section CA 08. If this Judge's name sounds familiar to you, it is because Judge Martin Zilber recently rendered a Public Records Enforcement Order (VIEW HERE) against the Village/Elected Official in a lawsuit for public records filed against the Village of Palmetto Bay, as well as against a Palmetto Bay elected official, in case No.: 2020-020589-CA-01 after a full hearing held on October 14, 2020.

I will continue to take time to review this latest lawsuit and report on details.

See PRIOR RELATED POST:  November 6, 2020, NEW LAWSUIT ALERT: LUXCOM files another lawsuit against Palmetto Bay.