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3.10 3.10 Litigation-Authorize Supreme Court Action—Barbone—East Slope Holding—West Mountain—9-10-12 RESOLUTION AUTHORIZING COMMENCEMENT OF SUPREME COURT ACTION AGAINST MIKE BARBONE AND/OR EAST SLOPE HOLDING, LP RESOLUTION NO.: ,2012 INTRODUCED BY: WHO MOVED ITS ADOPTION SECONDED BY: WHEREAS, East Slope Holdings, LP owns property at 59 West Mountain Road in the Town of Queensbury (Tax Map Parcel No.: 307.-1-29) and Mike Barbone (Barbone) is the owner and General Manager of the West Mountain Ski Center(the Ski Center) at the property, and WHEREAS, the property is in the Town's Recreation Commercial, (RC) Zoning District in which an Outdoor Concert Event is listed as an allowable use subject to a Special Use Permit obtained from the Town Planning Board, and WHEREAS, Barbone is currently advertising to the public that an Outdoor Concert Event will take place at the Ski Center on October 1Ith through Ie, 2012 but there is no Special Use Permit in place that would allow such an event, and WHEREAS, Barbone has been repeatedly advised of the requirements to obtain a Special Use Permit but has refused to file a proper application and has indicated in the past that he will not do so, and WHEREAS, the deadline to submit an application for the October Planning Board agenda was August 15th and although Barbone was advised of this deadline, he did not submit an application but contacted a Town Board member on September e and stated he would submit his application, and WHEREAS, based upon Barbone's past actions and the statements he has made in the past to the Town's Zoning Administrator,the Town Board remains concerned that Barbone may proceed with the advertised event regardless of whether a Special Use Permit is obtained, and WHEREAS, the advertisements for the event suggest that the event may include Transient Merchants or a Transient Merchant Market and there is no Transient Merchant License in place, and WHEREAS, the Town is extremely concerned that an event will occur as advertised without consideration of the numerous factors considered by the Planning Board prior to issuance of a Special Use Permit and that this will pose a danger to the public, a risk to the environment and have unacceptable impacts on the neighbors and surrounding community, and WHEREAS, Queensbury Town Court lacks injunctive power to require compliance with the Town Code, and WHEREAS, the Queensbury Town Board wishes to pursue preliminary and injunctive relief, including obtaining a Temporary Restraining Order if it becomes apparent that Barbone intends to violate the Town Code and proceed with an unapproved event, NOW, THEREFORE, BE IT RESOLVED, that the Queensbury Town Board hereby directs the Town Zoning Administrator to advise Town Counsel in the event Barbone fails to submit a completed application for a Special Use Permit sufficient to allow consideration in time for the October l lth advertised event, and BE IT FURTHER, 2 RESOLVED, that in the event Mike Barbone and/or East Slope Holding, LP proceed with such event without proper approvals, or in the event that Mike Barbone and/or East Slope Holding,LP obtain a Special Use Permit for the October event but fail and/or refuse to abide by any and all conditions attached thereto, or to obtain a Transient Merchant License if required, the Town Board hereby authorizes and directs Town Counsel to pursue action in the Warren County Supreme Court seeking: 1. A Temporary Restraining Order and other preliminary and permanent relief to prevent and/or disallow any event that has not been properly permitted at 59 West Mountain Road or any other site controlled by East Slope Holding LLC or Barbone in the Town; and 2. Fines and penalties, for the willful violation of the Town Code; and 3. An award of attorney's fees and costs required by this action; and BE IT FURTHER, RESOLVED, that the Town Board further authorizes and directs the Town's Budget Officer to arrange for payment of any Court and/or litigation costs related to this matter from the account(s) deemed to be appropriate by the Budget Officer, and BE IT FURTHER, RESOLVED, that the Town Board further authorizes and directs Town Counsel to file any necessary documentation to commence such proceeding and the Town Supervisor, Town Counsel, Zoning Administrator and/or Town Budget Officer to take any and all action necessary to effectuate all terms of this Resolution. 3 Duly adopted this IOth day of September, 2012,by the following vote: AYES NOES ABSENT : 4