The Morton Grove Organization LLC

Organization Web Site: http://morton-grove.org/about.htm

----- Original Message -----
From: "Postmaster-MGO" <postmaster@morton-grove.org>
To: "Len Hill"
Sent: Tuesday, September 09, 2003 6:34 AM
Subject: Re: RLUIPA

> Dear Mr. Hill;
> Recently you requested a short history of our situation here in Morton
> Grove, Illinois. Since that request, we have, in fact, filed a Federal
> Lawsuit against the Village of Morton Grove; many of the Village officials
> as well as two of the incarnations of the religious group infringing upon
> our neighborhood. A copy of our suit will be on our web site shortly. The
> short history you requested can be found at
> http://morton-grove.org/about.htm but I have enclosed a copy of the text
> below for your use. Please feel free to link to our site.
>
> =================Text of short history of MGO LLC===========
>
> Prepared for and at the direction of counsel in anticipation of
litigation.
>
> Situation Overview
>
> In the spring of 2002, overwhelming traffic finally exhausted the patience
> of a quiet Morton Grove neighborhood. The genesis of The Morton Grove
> Organization LLC can be found in the exhaust fumes and chaos of that
> traffic.
>
> In the 1989, a local elementary school was purchased under contentious
> circumstances by a Chicago-based Muslim organization (The Muslim Community
> Center of Chicago) to be used as a parochial elementary school. It soon
> became obvious that it was being used as a community center and house of
> worship in violation of Morton Grove zoning laws.
>
> In May 2002, after many unfruitful attempts to negotiate relief local
> residents petitioned the Village of Morton Grove for Resident Only
parking.
> This request was subject to public notice and open hearings.
>
> During these hearings, it was brought forward that the Muslim Community
> Center (MCC) planned an expansion of the school which was to include
almost
> doubling the footprint of the building and paving over all of the
remaining
> green space surrounding the school in violation of long-standing Village
> Zoning requirements which specifically stated that community centers and
> houses of worship required a special use permit and that such permit must
> meet seven specific standards..
>
> The MCC filed for a Special Use Permit (SUP), asking the Village to allow
> the school to be exempted from the restrictions attendant to R-2 zoning .
>
> By Village ordinance, the application for an SUP was subject to public
> notice and open hearings. Neighbors opposed to the conversion of the
school
> into a Mosque and regional gathering center argued that the planned
> expansion and use of the property was overwhelming in size; required over
19
> exceptions to long established zoning ordinances and failed to comply with
> most of the seven required standards for issuance of a special use permit.
> The Planning and Zoning Commission held an unprecedented 24 + hours of
> hearings on three separate nights over three months.
>
> The Planning and Zoning Commission then unanimously voted to recommend
> denial of the application and the Village Board of Trustees subsequently,
> voted unanimously to deny the MCC application. At the conclusion of the
vote
> by the Village Board, a local resident asked when the neighbors could
expect
> the Village to issue a cease and desist order to the MCC requiring them to
> stop the illegal and non-conforming usage of the property. The response by
> the Corporation Counsel of Morton Grove, Mr. Gabriel Barrafato was; "We
will
> have to look into that. We'll take it under advisement."
>
> Throughout the spring and summer of 2003, the MCC congregation continued
> using the facility for regular services as well as special celebrations
that
> attract up to 2000 people. In August 2003, the MCC through their attorney
> tried for a third time since 1990 to have the Village vacate a parcel of
> public land (the Capulina Ave. Right-of-Way) to facilitate the building of
> their Mosque and parking lot.
>
> It has become startlingly clear to concerned homeowners in Morton Grove
that
> the assertion of special privilege by religious landowners will have far
> reaching effects on their neighborhood. In states across the nation, a
wide
> variety of religious groups are seeking to exploit the special privileges
> granted to them by RLUIPA to build sanctuaries, homeless shelters, banquet
> halls and parking lots.
>
> Residents of Morton Grove have formed the Morton Grove Organization LLC
(MGO
> LLC) to challenge the actions that have transformed a school in their
> neighborhood into a regional Mega-Mosque and a Community and Social center
> drawing patrons from as far away as Wisconsin and Michigan .
>
> As one of their first official acts, MGO LLC plans to file a lawsuit
> against the Village of Morton Grove and the Muslim Community Center. The
> lawsuit seeks to halt the use of specific residentially zoned property as
> places of worship and for other non-conforming activities. This litigation
> is expected to result in a direct Supreme Court challenge to the
> constitutionality of RLUIPA.
>
>
> Prepared for and at the direction of counsel in anticipation of
litigation.
>
> ==================END OF SHORT HISTORY TEXT===========
>
> Thank you for your interest in our situation.
>
> Regards,
> Pat Kansoer - Founding Member; The Morton-Grove Organization LLC.
> http://morton-grove.org
> "Filius Lux Spiritus Veratatum"
>
> ----- Original Message -----
> From: "Len Hill"
> To: <postmaster@morton-grove.org>
> Sent: Thursday, August 28, 2003 5:55 PM
> Subject: RLUIPA
>
>
> Mr. Kansoer,
>
> In late July, you wrote to Larry Faigin with regard to the story that
> appeared in the Wall Street Journal about the land use dispute in Hancock
> Park, California. The group we have formed, The League of Residential
> Neighborhood Advocates, has now launched our website, TheLRNA.org, and we
> are deeply enmeshed in litigation with the City and the Congregation.
>
> We would very much like to post a summary of your situation on our
website.
> We believe that neighborhood groups such as ours need to be aware of the
> vast array of challenges around the country. Could you provide us with a
> brief history of your situation so that we might post it?
>
> Also, I encourage you to review the legal brief that is available on our
> website. It might help your attorney formulate various different lines of
> defense.
>
> Many thanks
>
> Len Hill