1214 HOYT AVE 2016-01-01 MF Import

� � LAW OFFICES OF NEWTON, NEWTON, KIGHT, HAMMER & ADAMS IB20 - 32+e STREET v. O. BOx l9 FATNUR M. NEWTON •ivr♦ AFE4 CODC 2D6 NEIJRY T NCWTON EVERETT, WASMINGTON TELEPNONE: 259-5106 R. MICMGEL NIGMT S�BIOd 9ARqY P. HAMMER TMOMq$ O.AOAMS CMAq�[S R. pCNNCT 0[ COUNiCI February 14 , 1985 � C� � C� � d � p� � rg 14 ��b� City of Everett Planning Department "ITX OF : , �i�E'TT 3002 Wetmore Avenue rlarnung uept. Everett, WA 98201 Re: Duplex at 1214 Hoyt, Everett Gentlemen: We represent Ms. Carol Hill , to whom you wrote on December 20 , 1984 . She was given until February 15 , 1985 , to appeal a determinatioa that the use of her property at 1214 Hoyt, as a duplex, constitutes an illegal structure. Please be advised that we are appealing that deterr.�ination on behalf of our client, Ms. Hill. Our basis for the appeal is the pre-existing use of the p;:operty as a duplex long before any zoning restrictions were on the property. Mr. Frank Willit, presently a resident at 1023 Grand Avenue, Everett, purchased the 1219 Hoyt property in 1949 , and sold it in 1960 . Durinq the entire period of time that he owned the property, there were two living units , one being on the main floor and one being in the basement. He rented the base- ment to various tenants during the entire period of time that l�e owned the property. I should also point out that the City allowed Ms. Hill to remodel the premises in 1981 , and gave her a certificate of occupancy in 1982 for the basement apartmeat. It is our position that the pre-existing use results in the City being unable to stop Ms. Hill from continuing to use her property as it has been used for over 36 years. Further, since Ms. Hill is not making any request of the City with respect to the property, such as the right to remodel or what have you, it is our position that she has no obligation to file any app].ication for a non-conforming use.