2/16/2024 <br /> <br />5 <br />Thus, while the Applicant appears to have responded to the request for deeds in the Incomplete Notice, <br />the deeds supplied are not given any context, appear to include deeds for other properties (not the subject <br />property), do not include all of the deeds for the subject property, and fails to demonstrate that the subject <br />property is a legal lot. Therefore, the deed record submitted by the Applicant is incomplete and contains deeds <br />that are not relevant to the legal lot analysis. As a result of these shortcomings, the Applicant has failed to <br />demonstrate compliance with EC 9.8210(3) by establishing that the subject property is a legal lot. <br /> <br />III. Potential record issues <br /> <br />In fairness to the Applicant, the application asserts, as mentioned above, the submission of several <br />materials that were absent from the record available to the public. Whether the fault lies with the Applicant or is <br />the result of an error when compiling the record for public comment is impossible for the public to ascertain. <br />Regardless, those materials are absent from the record, renderig the application deficient of substantial evidence <br />regarding many of the applicable criteria as explained above. <br />IV. Conclusion <br /> <br />For the above reasons, Christine Butler and Sandra Stevens request that the middle housing land division <br />application, File No. MHT 23-24, be denied. <br /> <br />Respectfully submitted, <br />Charles W. Woodward, IV <br />Attorney for Christine Butler and Sandra Stevens <br /> <br />