HomeMy WebLinkAbout1999-03-29 BRIEWWN OF '3ROTON
March 29 1999 MAR
Colleen Pierson
Town Clerk
Town of Groton
101 Conger Blvd .
Groton , NY 13073
Dear Colleen .
Enclosed is a copy of the testimony prepared by me and read into the record by
Mahlon Perkins, Esq . at the public hearing, March 18 , 1999 , on the application by
Jeffery and Kimberly Langer for site plan review.
Please see that it becomes part of the official documentation associated with the
hearing.
I am also sending a copy to Monica Carey as acting chair of the planning board .
Very truly yours,
Van C . Travis, Jr.
t 1
Testimony at the Public Hearing
For Site Plan Approval
For Sirens, LLC
By
Van C . Travis, Jr.
10 Cemetery Lane
McLean, NY
I am Van Travis of McLean , NY, one of the co-owners of the property at 3 Stevens
Rd . and am named in the application before you . I am unable to attend this
evening and am having Mahlon Perkins , Esq . read my comments into the record .
I believe that you have a most difficult case before you . On the surface it is a
simple request for an eating and drinking establishment, or what we commonly
would call a tavern and restaurant which is what the Elm Tree Inn has been for
over 100 years . We of McLean were looking forward to seeing the Elm Tree Inn
reopen ever since Joe and David Bail closed down their operation . Each rumor of a
possible purchaser created excitement in the town with the hope that the Inn
would be restored to its previous status as a good restaurant and tavern . My wife
and I, who operate the business next door to the Elm Tree Inn , have been
especially desirous of having a restaurant there as our customers very much need
a place to eat, especially lunch . You can imagine our disappointment when what
we got was a strip joint.
The application before you, taken at face value, does not propose anything to
which I have any objection . Therefore, I can stand here and say without
equivocation that I fully support the establishment of a restaurant and tavern at
the proposed site . It would be an economic asset to McLean and the Town of
Groton .
However, I strongly believe that this application is a sham, put forth in a scheme
by Mr. Chatfield, in which there is no intention of operating anything even
remotely resembling an eating and drinking establishment. Mr. Chatfield has told
several people that there is no expectation on his part or the Langers that
approval will be granted and that it is his desire to appeal the Town Code on
Sexually Oriented Businesses; to have it declared unconstitutional ; and beyond
that, he will sue the Town of Groton on behalf of his clients for $ 8 - 10 million ,
making both him and them wealthy and the Town of Groton bankrupt. How
disappointed they would be if you granted them approval .
I believe the Langers have no desire to do anything that would involve the
investment of time, money and effort necessary to operate a restaurant. As they
have openly testified under oath in public proceedings in which they have been
involved, they have consciously chosen the area of adult entertainment as their
field of endeavor in the same way that others might choose to operate a gas
station , convenience store, dry goods store or dry cleaning service .
The eating and drinking establishment which they did operate for approximately a
year at the site under consideration , never offered as near as anyone can
determine any food to eat. My own visit to the establishment in December, 1997,
sitting in the area of the bar for approximately one hour, never revealed so much
as a potato chip, pretzel or even Mr. Chatfield' s famous pickled egg. Also, sworn
testimony in court by a number of people who visited Sirens never mentioned
anything to eat. Investigation by the New York State Police revealed a kitchen that
was filthy, the stove was not connected to a power source and the refrigerator was
not plugged in . Given all of this, it seems highly unlikely that the Langers will
suddenly be possessed with a zeal for all the hard, sweaty and unglamorous work
associated with the restaurant business as opposed to the relative ease of an adult
entertainment business where the workers pay the owners for the privilege of
performing.
As you consider your decision , there are a number of things that you need to
know. I am going to mention several .
First, the sketch plan that was submitted to you is inaccurate in its representation
of the existing conditions on the property . The drawing was produced in 19 70 .
Since that time, there has been a major fire at the Inn , rendering this rendition
obsolete and unrepresentative of the modifications made since that time . The
location of the dumpster on the sketch plan is not where it presently exists nor
where it has ever existed since the Langers have occupied the property. I believe
that you have received additional drawings from what were presented at the
November meeting. The floor plan that has been submitted is also of questionable
accuracy . We know from sworn public testimony that the facility contains a stage
for entertainment performances and lap dance booths . Neither appears on the
drawings . While their existence is not pertinent to site plan review, it does raise the
question again of whether information provided for your review and consideration
is accurate and truthful . I would recommend that you dispatch the Groton Code
Enforcement Officer to the site to determine whether the information before you
is true and accurate .
Second, I believe that you are lacking the common , normal information that is
necessary for you to render a decision regarding this application . As previously
stated, you have a sketch plan , created by the applicants, that is inaccurate and
about which they are unable to reasonably respond to your questions despite
having occupied and operated on the property for a year. It is normal to ask for a
description of their general plans of operations a business plan if you will . They
don't have one . They don 't know whether it will be a sports bar, a dance bar, a fine
French restaurant; a gay bar, a bikers bar or might I suggest a nude bar. I
maintain that it defies credibility that anyone genuinely plans to enter into
business and has no idea about what they plan to do . We have heard Mr. Chatfield
bellow, bluster and obfuscate about trade secrets and competitive advantage . With
regard to all of the alternatives for an eating and drinking establishment,
competition abounds in the Cortland-Ithaca area and this contention regarding the
need for secrecy is pure deception . Each of these alternatives that I have described
inherently carry with them different effects upon the site and the adjoining
neighborhood . Without any information regarding their operational plans, you
are unable to decide if the activity is compatible with the neighborhood and how
you must restrict the activities through the permit process to insure compatibility
between the business and the primary residential nature of the zoning district.
Any other applicant who stonewalled the board as Mr. Chatfield has done would be
sent packing. I recommend that you do the same with him . When he is willing to
provide you with the necessary information , you should be willing to consider the
application . Your other alternative, of course, is to restrict the approval so that
they are left with no alternative except to operate a legitimate eating and drinking
establishment.
Third, Mr. Chatfield has testified that it is their plan to open without so much as
moving a pebble, driving a nail or disturbing an iota of earth in reoccupying the
facility. Let me start off by suggesting that they need to move the dumpster if
they want the sketch plan to represent the existing conditions . The suggestion
that they are going to operate a restaurant, to use a more common term , without
doing anything to the premises, when they are moving into a building that has no
electricity, no natural gas, no propane service, no running water and no heating or
air conditioning and has laid empty for months during sub-freezing weather is
contrary to what we know will be the case . The kitchen , we know, is not
operational and has no means by which to prepare food . For this facility to become
an eating and drinking establishment, the ZBA definition of such not withstanding,
will require major work. Those of us who are knowledgeable of the property
believe that health department approval for food preparation and service is
impossible without major structural renovations to prevent access to rodents and
insects . Mr. Chatfield' s contention that there will be no construction or renovation
activity seems impossible if they are to operate an eating and drinking
establishment. I believe that the probability that these people would open a
restaurant is essentially zero and that is why they have refused to discuss their
plans for a restaurant with you ; they have none . This is just further evidence that
the application before you is a sham . The information provided and the testimony
given by the applicants contradicts itself and therefore you are unable to make a
reasonable decision without clearer and more precise information .
Fourth , I believe it is clear that the only business that the Langers have any
interest in operating at the Elm Tree Inn is the one that they previously operated,
a totally nude dancer juice bar. I believe that section 317 . 2 of the Town Zoning
Code prohibits that activity in the M - 1 district in which the Elm Tree Inn is located .
That section of the code was enacted prior to the date of the application that is
before you, and it prohibits the type of activity that the Langers previously
conducted at the site .
In further support of my contention that the Langers plan to continue the
operation of a nude dancer juice bar, I refer you to their statement on the Short
Environmental Assessment Form , item 6 . There they state, in response to the
request to describe the project briefly, "Reopen eating or drinking establishment
without any changes whatsoever. " How much plainer can their intentions be . If
they were to open a restaurant it would not be a reopening as no restaurant
previously existed .
If approval for an eating and drinking establishment is given , it is essential that the
special permit specifically reference the prohibition of any sexually oriented
business at the site
Fifth , I would call to your attention that nowhere in the record is there evidence of
the Langers, who are the applicants, having participated in this proceeding other
than to be present. While I would be the last to deny them legal counsel, the fact
that they have not uttered a single word in all of these proceedings indicates
strongly to me that the true applicant here is notJeffery and Kimberly Langer, but
rather Mr. Chatfield . He has stated to others his intentions to use this case to
advance his practice and to increase his financial well being by suing and
bankrupting the Town of Groton . I would also note that he was quoted in the
Syracuse Herald-American that he is working on this case without pay. Perhaps the
Langers are his cousins and therefore his willingness to work pro-bono, but I have
heard nothing to suggest that. Thus, it seems clear that what the people of
McLean , the Town of Groton , the State of New York and all others associated with
this case are being subjected to is a thinly veiled attempt by Mr. Chatfield to
advance his own personal interests .
Lastly, this site plan process requires an environmental review. Within it questions
are raised as to noise and other external events which would have an effect upon
the surrounding area . Seemingly, such an eating and drinking establishment as
proposed here would have little effect outside the confines of the building.
However, such has not been the case during the period the Langers have occupied
the property .
Again let me point out the Langer' s response to item 6 of the Short Environmental
Assessment Form states, "Reopen eating or drinking establishment without any
changes whatsoever." Let me tell you what "without any changes whatsoever"
means to us of McLean by reciting a long list of incidents of the past year.
Mr. Chatfield noted 20- 30 noise complaints over the course of a year that he
claims were baseless . They were baseless if you live in Tully, but, if you live in
downtown McLean and are trying to sleep at la . m . , they are very much a reality .
The law enforcement agencies responding to the calls did in fact require that the
volume be turned down . Yet, as Mr. Chatfield avows, the good neighbor policy of
the Langers was repeated upwards of 30 times .
The record needs to showJeffery driving his truck at a high rate of speed through
the streets of McLean during its annual community quilt show, garage sale,
Firemen ' s barbecue and church box luncheon endangering people strolling in the
streets and causing them to move into the ditch to avoid being hit.
The record needs to showJeffery driving his truck up and down selected streets in
McLean in what may be described as a stalking fashion to harass certain residents .
The record needs to showJeffery standing in the front yard of the Elm Tree Inn
and during the event just cited calling lady visitors to the event, "Cunt" ; lady' s who
were totally innocent of any action that would provoke any kind of greeting other
than hello and welcome to McLean .
And the record needs to show dancers from Sirens standing in the front yard of
the Elm Tree Inn flashing their bare breasts at passing motorists and Jeffery
standing in the front yard of the Inn and grabbing his crotch as a signal of
defiance to me and others as we drove by.
Mr. Chatfield has stated that he cares not what the people of McLean think. We
the people of McLean object to what has been a continuous avoidance of candor by
Mr. Chatfield since the inception of this process, the continual display of public
lewdness by the Langers and their dancers, the assault upon the safety of innocent
visitors to community events and their incessant disturbance of the peace through
excessive noise at hours when normal people are long since in bed and asleep .
"Without any changes whatsoever" means a continual display of public lewdness,
obscene language and behavior, and disturbance of the peace through deliberate
attempts to produce excessive noise .
For these reasons we contend that the activities of the Langers by whatever
description they describe their business, are not in harmony with the residential
and commercial character of the neighborhood .
This is a case where you can decide based on past performance rather than
speculating on the future . The Langers have proved to be a detriment to the
community and rather than trying to win the people over by being quiet and
considerate citizens they have chosen to disturb the peace, offend normal human
sensibilities, and jeopardize the public safety . They have openly and defiantly
stated that their intent is to make life in McLean as miserable for the residents as
possible . During their time in town they have done just that. With that as a
stated objective, one can reasonably predict what their future behavior will be .
No community in America would want people who act as I have described as a part
of their community . We of McLean surely don 't. I have described a long list of
conditions that have existed during Sirens operation in McLean . They are
conditions that you as a board must control through the permit process .
Last week, I hauled out the Special Permit that we received when my wife first
opened her business in our home . It controlled everything including noise and
hours of operation . If you can do it to me, you can do it to them . If they truly
want to operate a legitimate restaurant and tavern fine, but I don 't think so . If
you find it necessary to grant approval to this application , then I hope that you
will take a major portion of the next 62 days in which you have to deliberate to
insure that we don't get from the Langers what we have had in the past.
Respectfully submitted,
Van C . Travis, jr.