A hambersburg, PA 17201

Email: pmca@pacodealliance.com

Phone: 717 496-4996 Fax: 717 446-0586

Website: http://pacodealliance.com/

Ms. Linda Atiyeh, President November 19, 2016

Gettysburg Investors, LLC.
30 York St
Gettysburg PA 17325 Via: First Class & Certified Mail

RE: 26 York St (Gallery 30), Gettysburg, PA 17325; Parcel Number: 16007-0220---000

Notice of Continuing violations of various Borough Ordinances

Ms. Atiyeh;
This letter is a Legal Notice. You should take this to your attorney at once.
This letter is a Notice of Violation.

This letter outlines numerous ongoing violations of various Borough Ordinances and requires your
immediate attention.

| am in receipt of and responding to your November 18, 2016 email to Charles Gable et. al titled “Re: Gallery
30/Gettysburg Investors LLC Code Violation”. | am also in receipt of the November 16, 2016 letter to you from
Becky LaBarre, Director of Planning and Historic Preservation for the Borough of Gettysburg and of the
November 7, 2016 letter to you from Scott Weaver, Borough Code Enforcement Officer. | will be the point of
contact going forward with this enforcement action. This should eliminate any confusion on your part. | will
be very clear and concise with my communications.

Please direct any questions or concerns to me, in writing, at the address in this letter. Though you may wish
to speak informally, from this point forward in the enforcement actions before you, for your protection, and
for a clear record all official communications must be in writing. | will do the same.

Please bear with me as | guide you through your “confusion” with Gettysburg Borough’s Ordinances,
requirements, and procedures. Please be advised that this letter contains sufficient information for you to be
able to make decisions to bring your facility into compliance or otherwise sufficient information for you to
make the necessary appeals.

In Paragraph 12 of your recent email communication with Manager Gable you suggest your need for
Clarification of what law is violated and how it is violated along with to whom you must apply to or appeal to,
in order to find resolution. | will attempt to answer your request. You suggest that Gettysburg is “...steeped in
American History and our love and practice of the rights and values of all men and women...” A worthy goal for
both you and I. Your suggestion caused me to remember and to reflect on the words of our 16th President of
the United States who said - "Let reverence for the laws, be breathed by every American mother, to the lisping
babe, that prattles on her lap - let it be taught in schools, in seminaries, and in colleges; let it be written in Primmers,
spelling books, and in Almanacs; let it be preached from the pulpit, proclaimed in legislative halls, and enforced in
courts of justice." Thank you for the remembrance.

At the very least, this letter provides adequate details and notifications of your continuing violations and the
opportunities to become compliant. Enough so that a competent attorney of your choosing should be able to
further provide you either good guidance relative to procedure and a compliance path, or defend you from
the openly defiant, daily occurring violations at this property. | strongly suggest you seek the advice of such
a competent attorney to assist with your understanding of these issues and the pathways to compliance.

This letter is a Legal Notice. You should take this to your attorney at once.

On Monday, November 7, 2016, Code Enforcement Officer Weaver sent Gettysburg Investors a reminder and
a request, by first class mail, to remove nine signs from the west wall of 26 York St. Officer. Weaver clearly

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cited the Gettysburg Borough Sign Ordinance; Ordinance Number 1373 - 10, Section 19 - 111 (3) referring to
unsafe, abandoned, and illegal signs. Portions of which are included in this document. Officer Weaver gave
you 10 days to remove the signs. Your 10 days were up on November 17, 2016. A site investigation that day
revealed they were still in place.

On Wednesday, November 16, 2016 Gettysburg Investors once again received a written communication
regarding the violations on or about their property at 26 York St., Gettysburg. This communication was from
Ms. Becky LaBarre, Director of Planning and Historic Preservation for the Borough of Gettysburg. In this
letter Ms. LaBarre clearly indicates that you continue to be in violation of the Gettysburg Borough sign
ordinance, as mentioned above. However, in her attempt to assist you in resolving the open violations at 26
York St., Ms. LaBarre has offered what she considers to be two options that have the potential (or had the
potential) to assist in resolving those violations.

In this very same letter Ms. LaBarre advised you of the potential penalties for your continuing
noncompliance and offered guidance relative to the appeal process. Please be advised that your continuing
discourse, delay, pleas of confusion, etc. do not act as a stay in this matter and that the violations are daily
occurring and numerous in nature. | strongly advise you to seek legal counsel in this matter, particularly if
you continue to defy compliance.

Paragraph Four (4) of your November 18, 2016 email to Borough Manager Charles R Gable, et. al suggest
that you may be confused and could not identify the specific laws, appeal process, time frames,
interpretations or challenges to the various communications that you have had relative to these numerous
violations. As stated multiple times above, | strongly urge you to seek legal counsel for any of the concerns
that you have either mentioned or, as of yet, failed to verbalize. Having said that however, | will suggest that
all borough codes and ordinances are publicly available online via the borough’s website
(http://www.gettysburg-pa.gov! ) and may be accessed 24/7 for your perusal, consideration, and review.

In addition to the online presence of Borough Code of Ordinance and of the online presence of the
necessary forms for permitting, | have enclosed for your use and referral a COA (Certificate of
Appropriateness) Application and a Sign Permit Application. For compliance these should each be filled out
for every sign that you intend to display in the Borough at the 26 York Street location. As outlined above you
can clearly see that all nine of the identified signs in Officer Weaver's original letter are required to obtain
permitting or be removed immediately from the structure. Indeed, compliance means immediate removal
then processing of applications for those which you choose to reinstall. | understand that there may exist a
different viewpoint based on your previous arguments. That would be a matter for the HARB and the Court of
Common Pleas. Those two governmental bodies are your avenues of appeal. HARB relative to any issue
relating to the HARB Ordinance and the Court of Common Pleas for most other ordinance appeals other than
any Zoning issues that you may need heard. Zoning issues are correctly heard by the Zoning Hearing Board.

Relative to your inquiry about timeframes - all Notices of Violations are immediate in nature. Meaning that
the violations occurred on the day they were first noted and seem to be openly, continuously, defiantly, and
notoriously ongoing in a daily fashion. Regardless of deadlines, once you are cited the action will go to the
first day of the violations as noted in the record. It appears as if the Borough Staff you have been dealing
with to this point, have been attempting to seek voluntary compliance in a very gentle manner. It is
noteworthy that they have several times not only offered guidance and assistance but that they have actually
extended enforcement deadlines in an ever increasingly difficult effort to obtain that voluntary compliance
on your part. | applaud them for their efforts, but the record seems to suggest that compliance has not been
forthcoming nor is it expected to be, as no applications have yet been received and no appeals have been
applied for while the violations appear openly continuing, meaning that the violations continue in open
defiance to Borough Ordinance in an affront to the laws, dignity, peace, harmony, and good order of the
community that so strongly supports your business and all others within their borders.

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Absent a procedure for appeal of a particular Ordinance (such as
Code Board of Appeals) relief may be sought through the Adams
advice and guidance of your attorney. You have the right to legal
comply with these Notices of Violation you should take this letter
an attorney or if you cannot afford one please contact the PA Bar
Box 186, 100 South Street; Harrisburg, PA 17108; Telephone Number:
the Zoning Hearing Board or the Building
County Court of Common Pleas. Seek the
counsel. If you do not intend to fully
to your attorney at once. If you do not have
Association Lawyer Referral Service; P.O.
800-692-7375.

Chapter 19 of the Borough of Gettysburg Code of Ordinance is the sign ordinance. Paragraph 19 - 103 is a
definition paragraph for the sign ordinance. Signs are clearly defined as follows:

SIGN
Any structure, device or object that incorporates lettering, logos, colors, lights, or illuminated inert gas tubes visible to
the public from a building or structure, which either conveys a message to the public, or intends to advertise, direct,
invite, announce, or draw attention to goods, products, services, activities, or facilities, excluding window displays of
merchandise or noncommercial items. The use of the term "sign" in this Part shall not be interpreted as including the
supporting structure of a sign.

Violations of the sign ordinance are significant and daily occurring. Each sign and each day are considered
separate violations; Section 19-114 is the penalty section of the Sign Ordinance.

§ 19-114Penalties.
[Ord. 1373-10, 3/8/2010]
Any person who shall be convicted of a violation of any provision of this Part shall be sentenced to pay a fine of not
more than $600. Every day that a violation of this Part continues shall constitute a separate offense.

Section 19-104 contains the permit requirements as outlined below:

§ 19-104Sign Permit Requirements.

[Ord. 1373-10, 3/8/2010]
Only signs which refer to a permitted use or a use approved by special exception or variance pursuant to the
provisions of the Zoning Ordinance are permitted, provided that such signs conform to the provisions of this Chapter.
A. Permit. Except as otherwise provided in § 19-105 hereof, no person shall erect, place, alter, locate or relocate a
sign anywhere in the Borough until a sign permit for such has been issued by the Borough.
B. Fee. The applicant shall pay a fee that will accompany the sign permit application. Such permit fee shall be set by
resolution adopted from time to time by the Borough Council.
[1] Editor's Note: The current resolution is on file in the office of the Borough Secretary.
C. Historic District. In addition to the requirements set forth in this Part, the Historic District Ordinance and the
Zoning Ordinance may impose additional regulations and requirements for signs to be erected in the Borough.

Violations of the Permitting requirements of the Gettysburg Borough sign ordinance are significant and daily
occurring. Each sign and each day are considered separate violations; Section 19-114 is the penalty section
of the Sign Ordinance.

§ 19-114Penalties.
[Ord. 1373-10, 3/8/2010]
Any person who shall be convicted of a violation of any provision of this Part shall be sentenced to pay a fine of not
more than $600. Every day that a violation of this Part continues shall constitute a separate offense.

Illegal Signs are specifically enumerated at Ordinance Section 119-111 (3) as outline below. Each sign and
each day are considered separate violations; Section 19-114 is the penalty section of the Sign Ordinance:

§ 19-111Unsafe, Abandoned and Illegal Signs.

[Ord. 1373-10, 3/8/2010]

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1. Unsafe. If the Borough shall find that any sign or other advertising structure regulated herein is unsafe or insecure,
or is otherwise established to be a nuisance by the Borough, the Borough shall give written notice to the permittee
thereof. If the permittee fails to remove or alter the structure so as to comply with the regulations herein set forth
within 10 business days after such notice, the Borough is authorized to remove or alter the sign and to collect, in the
manner provided by law, the costs associated with such removal, together with a penalty of an additional 10% from
the owner of the sign or of the property. The Borough may cause any sign or other advertising structure that
constitutes an existing and immediate danger to persons or property to be removed without prior notice.
2. Abandoned. When a permanent sign no longer advertises an existing business conducted on the premises for 12
consecutive months, the sign shall be presumed to be abandoned. The Borough, upon determining that all business
operations have ceased for a period of 12 consecutive months, and noting that a sign exists, shall notify the owner of
the premises in writing that the owner must either provide to the Borough satisfactory written evidence that the sign
was not abandoned or remove the sign within 45 days after the date of the notice.
3._ Illegal. If the Borough shall find that a sign has been placed without the required permit or is in violation of any
condition set forth in the sign permit issued by the Borough or is in violation of any regulation contained in this Part, it
shall give written notice to the person owning the property where the illegal sign is erected or to the permittee or
owner of the sign. The illegal sign shall be removed by the person owning the property or the permittee, as
applicable, within 10 business days after such notice.

Illegal Signs as defined by the Gettysburg Borough sign ordinance are violations of the ordinance and are
significant in nature and daily occurring. Each sign and each day are considered separate violations; Section
19-114 is the penalty section of the Sign Ordinance.

§ 19-114Penalties.
[Ord. 1373-10, 3/8/2010]
Any person who shall be convicted of a violation of any provision of this Part shall be sentenced to pay a fine of not
more than $600. Every day that a violation of this Part continues shall constitute a separate offense.

Section 19-121 is the Section relative to Signs in the Historic District.

Because the subject property is located in the Historic District additional requirements apply as follows:

§ 19-121Signs in the Historic District.

[Ord. 1373-10, 3/8/2010]
1. General. Signs erected and/or located within the Historic District shall conform to all applicable provisions and
regulations contained in this Part and, in addition, must undergo a design review by the Borough for conformity with
the guidelines set forth in the Gettysburg Design Guide. The Borough may determine that a review by HARB is
necessary prior to the issuance of a sign permit pursuant to the criteria set forth in the Historic District Ordinance.
[1] Editor's Note: See Chapter 11, Historic Districts.
2. Historic Markers. Historic markers shall not be considered as signs for the purpose of this Part, but will be
reviewed by HARB consistent with the Historic District Ordinance.
3. Placement.
A. Permanent signs erected in the Historic District shall not cover architectural details, to include, but not be limited
to, arches, sills, moldings, cornices and transom windows.
B. No sign or permanent external advertising display of any kind shall be erected, altered or used in the Historic
District except for advertising or informing the public of service, business, occupation or profession carried on, in or
about the property on which such sign or permanent external advertising display appears.
4. Procedures. When the Borough determines that HARB review is needed for a sign proposed to be erected in the
Historic District, the following procedures shall apply:
A. HARB shall consider the appropriateness of the proposed sign to the Historic District at its next regularly
scheduled meeting.
B._ In its considerations, HARB shall take into account the appropriateness to the architectural style and the period of
the building or other structure at which it will be located, material composition, shape, overall design, type of lettering,
illustrative material or logo, spacing, lighting, suspension, accuracy or statements on the sign pertaining to historical
or architectural matters, and compatibility of these factors with other signs in the Historic District. In addition, the

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HARB may advise on matters of grammar, spelling and punctuation, but HARB may not make a recommendation of
denial based on these grounds.
C. Upon a HARB recommendation for approval, the Borough shall issue a sign permit within 10 business days.

Penalty for Violation of the Historic District provisions are identical to those for the regular sign
requirements in that they are individual and daily occurring. This would be separate violations for the
subject property in addition to those listed above.

§ 19-114Penalties.
[Ord. 1373-10, 3/8/2010]
Any person who shall be convicted of a violation of any provision of this Part shall be sentenced to pay a fine of not
more than $600. Every day that a violation of this Part continues shall constitute a separate offense.

§ 19-106 General Sign Requirements.

E. Size Requirements. The total square footage of sign area allowed for a commercial property shall be determined
as follows:
(1) One square foot of sign for each linear foot of the frontage of the lot, but under no circumstances shall the total
permitted sign area for a single business or activity exceed 50 square feet, with the exception of billboards in the
Industrial District (IND), which shall be regulated pursuant to § 19-109H of this Part.
(2) Double-faced signs, including signs which incorporate two sign faces that are back-to-back and are not more
than two feet from each other, shall constitute one sign.
(3) For more than one business having a common frontage on a single commercial property, the owner of the
property may apportion the total sign area allowed among the several businesses occupying the property. A
commercial property having more than four businesses with common frontage may exceed the 50 square foot sign
size limit, but the total sign area for each business may not exceed the linear foot measurement of the frontage of
that business.
(4) In the case of a commercial property that has two separate street exposures on two different public streets or
alleys, the frontage on each street or alley shall be treated as a separate facade.

The walkway to the west of your structure is neither recognized as a public street or alley.

Issues related to the Historic District Ordinance (various sections of the HARB Ordinance relating to signs;
most specifically the sections most specifically relating to your situation):

§ 11-111Signs.
[Ord. 1118-91, 8/12/1991, § 111]
1. Procedures.
A. No sign or permanent external advertising display of any kind or for any purpose shall be erected or altered in the
Historic District until an application for a permit to make such erection or alteration has been reviewed by the Historic
Architectural Review Board, a certificate of appropriateness issued and a sign permit granted, except that the Code
Enforcement Officer may issue permits for minor sign changes as defined in § 11-104, Subsection 4D, without
referral to the full Board. However, he/she shall keep records of any permits issued for minor sign changes and shall
report these to the Board at its next meeting for inclusion in the minutes.
B._ No sign or permanent external advertising display of any kind shall be erected, altered or used in the Historic
District except for advertising informing the public of a service, business, occupation or profession carried on in or
about the property on which such sign or permanent external advertising display appears.
2.. Standards.
A. In considering appropriateness of proposed signs, the Board shall take the following into account:
appropriateness to the architectural style and period of the building at which it will be located, material composition,
shape, colors, overall design, type of lettering, illustrative material or logo, spacing, lighting, suspension, accuracy of
statements on the sign pertaining to historical or architectural matters, and compatibility of these factors with other

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signs in the Historic District. In addition, the Board may advise on matters of grammar, spelling and punctuation, but
approval may not be denied on these grounds.
B._ No animated, revolving, or moving signs shall be permitted.
C._ Illumination of any sign shall be indirect, fully shielded, or otherwise arranged so that illumination of the sign,
rather than the source of light, is visible from the public right-of-way. Internally lighted signs are prohibited.
D._ No freestanding sign shall be more than nine feet high.
E. Projecting signs extending more than two feet over any public walk or right-of-way shall be at least eight feet
above the walk grade and at least 14 feet above any vehicular right-of-way.
F._ No sign shall be erected at the intersection of any streets in such a manner as to obstruct free and clear vision or
at any location where, by reason of its position, shape or color, it may interfere with, obstruct the view of, or be
confused with any authorized traffic sign, signal or device.
G._No sign shall be located so as to prevent or hinder free ingress to or egress from any door, window or fire escape.
No sign shall be attached to a standpipe or fire escape.
H._ No sign shall be attached to, or placed on, any public utility pole or tree located within any public right-of-way.
|. Should the Code Enforcement Officer deem the design of a temporary sign inappropriate for placement in the
Historic District, he/she may refer the matter to the Board for review and recommendation to the Borough Council. A
time limit for a temporary sign may be recommended by the Board.
J._ All other requirements of any Borough sign ordinance must be adhered to, except that projecting signs in the
Historic District, regardless of area, may be made of combustible materials so long as they are not illuminated from
the inside.
3._ Historic Markers. Historic markers must be reviewed for approval by the Board. Such markers shall not be
considered as signs, but rather must conform to uniform requirements established for historic markers by the Board.

Penalties for Violations of the Sign Provisions of the Historic District Ordinance (note the violations are daily
violations with each violations and each day being a separate infraction:

§ 11-117Penalties.
[Ord. 1118-91, 8/12/1991, § 117; as amended by Ord. 1236-99, 12/13/1999, § 2]
For any and every violation of the provisions of this Part, the owner, general agent, or contractor of a building or
structure where such violation has been committed or shall exist, and the lessee or tenant of an entire building or
entire structure where such violation has been committed or shall exist, and the owner, general agent, contractor,
lessee, or tenant of any part of a building or structure in which part such violation has been committed or shall exist,
and the general agent, architect, builder, contractor, or any person who knowingly commits, takes part, or assists in
any such violation, shall be liable, on conviction thereof, to a fine or penalty not exceeding $600 for each and every
offense. Whenever such person shall have been officially notified by the Code Enforcement Officer or by service of a
summons in a prosecution, or in any other official manner, that he/she is committing a violation of this Part, each
day's continuance of such violation after such notification shall constitute a separate offense punishable by a like fine
or penalty. Such fines and penalties shall be in addition to any other fines, penalties and remedies provided by law
for such cases and shall be collected in the same manner as is provided in the Borough Code.

Having provided you with a significant amount of information outlined above, | again refer you to seek the
advice of your attorney. Referring specifically to your Paragraph 17 of the November 18* email you sent to
Mr. Gable, with CC to many many others, in which you asked that at our earliest opportunity to let you know
“how you (the Borough) would like to proceed...” and further outlining a few areas that you felt the Borough
had failed to provide clear and sufficient identification of the alleged violations. | will be proceeding as
follows:

Please consider the violations are numerous and flagrant. They are enumerated above in that you have
erected signage without the necessary permits and approvals and you have failed to remove the same or
otherwise obtain permits and approvals after due and timely notice (also referenced above). Your appeal
possibilities are outlined above as well. Contemplation of appeal or any further inability to comprehend the
issues at hand on your part does not constitute a stay. You have been quietly, quickly, and professionally
informed of the violations, offered several paths toward resolution, given notice of your appeal rights and

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been repeatedly advised to seek immediate legal counsel. You leave little room for any further efforts to
resolve your violations in a voluntary fashion and seem seriously bent on eliminating any vestige of goodwill
that has been held out to you by other staff members in their efforts to educate you and obtain that elusive
voluntary compliance. That appears to leave us with no other recourse than to file charges for the violations
as they have been presented to you.

In addition, during my review of your complaint | have discovered that you recently did apply to HARB for a
Certificate of Appropriateness for a hanging sign on the front facade of this business but the sign you
applied for was not the sign that was installed. The design appeared to differ significantly between what you
requested and what was then installed. Additional review indicates that you revised the application to more
accurately reflect existing conditions and that this violation is now in compliance.

Along with the matter mentioned in the previous paragraph, during a site visit late last week to observe the
illegal signage, | encountered an obstructed sidewalk in front of your business. The obstructions include
gourds on display stands, various other signs, presumably displayed as either advertising or merchandise,
along with other wares and decorations. Your display of merchandise or other occupation of the public
sidewalk must be kept to the innermost portion of the sidewalk. {Ordinance 21-223 (3)}. Consider this your
notice to remove the wares, products, displays, signs, etc. to the innermost portions of the sidewalk.

| have provided the specific Ordinance language and penalty section, relative to the sidewalk obstructions,
below for your use and referral. Please consult with your attorney at once regarding these violations as well.
Conviction on these charges could result in a fine of not more than $1000.00 per violation or Jail Time not to
exceed 90 days per violation. Each Day is regarded as a separate offence. If you cannot afford an attorney
we would refer you to please contact the PA Bar Association Lawyer Referral Service; P.O. Box 186, 100
South Street; Harrisburg, PA 17108; Telephone Number: 800-692-7375 or your local Legal Aid Office.

§ 21-2230bstruction of Sidewalks and Gutters Prohibited; Exceptions.

[Ord. 2/7/1905, § 2; as amended by Ord. 5/21/1914; by Ord. 104, 6/13/1968, § 1; by Ord. 1028-85, 8/12/1985; and by
Ord. 1166-94, 8/8/1994]
1. No person shall obstruct any sidewalk except as permitted by subsections (1) and (2) of this Section or by other
Sections of this Part of Chapter 21 of the Code of Ordinances of the Borough of Gettysburg.
2. Any merchant or other person engaged in business may occupy the innermost portion of the sidewalk directly
adjacent to the property line of such business with displays of merchandise.
3.. Outdoor dining areas shall obtain an annual permit and comply with the provisions in Part 11 of Chapter 13 of the
Borough Code of Ordinances, Licenses, Permits and General Business Regulations, Outdoor Dining Areas.
[Amended Ord. 1429-15, 5/11/2015]
4. No person shall obstruct the free flow of water in any gutter.

§ 21-228Penalties.
[Ord. 1028-85, 8/12/1985; as amended by Ord. 1236-99, 12/13/1999, § 1]
Any person, firm or corporation who shall violate any provision of this Part 2C shall, upon conviction thereof, be
sentenced to pay a fine of not more than $1,000; and/or to imprisonment for a term not to exceed 90 days. Every day
that a violation of this Part 2C continues shall constitute a separate offense.

A banner has also been discovered at the north end of the west wall of your structure that appears to be
unpermitted and is also in violation of the Borough sign ordinance, the HARB Ordinance, and of Borough
Ordinance requirements for the display of Banners (19-109G). Consider this Notice of Violation your notice
to remove the same and obtain proper permits and approvals for any future installation of this or a similar
banner. Please also note that the west side of your structure, while currently adjacent a walking surface is
not a side open to a public way, alley, or street. A review of Borough records indicates that there is indeed
no public street or alley along this side of the building. Please plan accordingly.

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In closing let me direct you to the Borough Website and Borough Office to find the necessary forms to
submit for all of your sign permits and the necessary HARB Approvals for those signs. When completed
return a signed copy of the appropriate application(s) to Borough Offices along with the appropriate fees for
processing.

Also note that you have been directed to remove all the signs from the building along the west side, they are
not permitted.
You have been directed to then apply for all necessary permits and approvals.
You have been advised to seek legal counsel due to the ongoing violations and your failure to comply.
You have been advised of your opportunity to appeal the issues in this matter. That appeal for matters of the
local ordinance appears to be heard by the Court of Common Pleas.

Sincerely,

TR Cn Male
R. Clem Malot, MCP
Chief Code Official
Pennsylvania Municipal Code Alliance

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