RECEIVED. a se 260 SARVIS LAW, LLC Bryn C. Sarvis, Esquire August 25, 2022 VIA PERSONAL DELIVERY ‘AND CERTIFIED MAIL ‘Town of South Congaree Town Council ATIN: Teresa K. Benjamin 119 W. Berry Road West Columbia, SC 29172 RE: Appeal of Revocation of License - Chapter 152.071 Served August 24,2022 Dear Madame Clerk ‘This leter serves as the appeal by Naomi Halter of the notice of business license revocation served upon her on August 24, 2022. The license was revoked on the purported basis that Ms. Halter failed to timely remove older mobile homes marked for removal by the Town. Asset forth at the hearing, many of the homes at issue were in town before the 1985 ordinance the Town claims isin play, and nothing was said by the Town about the ‘homes in almost forty years—until Ms, Halter took issue with the Town's revised. mobile home ordinance. Notwithstanding her belief that the hones are grandfathered, Ms, Halter has attempted to secure removal of the mobile homes for months through various sources, not just on the eve of the hearing. When Ms. Halter contacted DirtCheap at the time of the prior hearing, the cost of removal was suddenly higher by ‘$700 per mobile home. Thereafter, she placed Facebook and Craigslist posts to get interest in securing removing or demolition. She sought charities who could use them. ‘The individuals initially expressed interest and then backed out, likely overwhelmed by the volume of work. She contacted several individuals who were removal professionals, ‘She began speaking with Dirt Cheap in July and ultimately encled up, having no other 3424 Augusta Highway * Gilbert, SC 29054 + Phone: (803) 892-5525 -wmesarvislaw.comRECEIVED ‘Town of South Congaree Aue 26 202 Appeal of Naomi Halter ~ Business License Revocation Page 20f 2 ‘August 25,2022 choice, signing a contract to promptly remove the mobile homes at the cost of $30,600. “Atthe time of the hearing, the removal had already commenced, and Ms, Halter’s ‘undlerstanding was that the removal company would be continuing, weather ‘permitting, from day-to-day until the removal was complete ‘Members of law enforcement have acknowledged that she has made other improvements to the park, including cleanup of the dumpster areas, despite the fact ‘that she has repeatedly requested more law enforcement assistance in that regard given ‘that members of the public who are not her tenants are known to be using these dumpsters. She also removed the sign that was at issue, which she her workers did not have the ability to do. For years, Ms, Halter has provided low-income housing for minorities and other ‘marginalized groups. The Town has made clear during these proceedings that these folks are unwelcome. However, there is a housing shortage, and we question whether ‘the Town has thought through the impact of this number of suddenly homeless individuals if this license is revoked. Ms. Halter has diligently attempted to provide this housing, having grown up “dirt poor” herself, despite her significant medical issues, her husband’s death, the COVID-19 rent moratorium that left her making repairs ‘without rental income or the ability to evict for non-payment, her attempts to evict the tenants who do not properly care for their rentals, and the well-known challenges to securing people to provide work, particularly during COVID-19. By the time this appeal isheard, the homes at issue will have been removed. ‘To be clear, Ms. Halter is attempting to cooperate with the Town and abide by the ‘ordinances that apply to her. Her livelihood, at over 70 years old, should not be taken. from her when she has remedied the problem and is working so hard to clean up the parks. Sincerely yours, for Naomi Halter