HomeMy WebLinkAboutCC - Applicant's Appeal Narrative DEVELOPMENT REAL PROPERTY ZONING
CLARK
WARDLE
Geoffrey M.Wardle
(208)388-3321
gwardle@clarkwardle.com
Via Citizen Access Portal Submission
April 15, 2026
City of Meridian
Meridian City Council
33 E Broadway Ave
Suite 102
Meridian, ID 83642
RE: City Council Review—Appeal of Denial on ACZCU-2026-0002
CW File#: 24446.1
This appeal of Meridian Staff's denial of CZCU-2025-0002 is submitted pursuant to Section 11-5A-7 of
the Meridian City Code.
In support of this request, we provide the application materials that were previously submitted and the
following analysis.
A. Introduction
We represent Long Dog, LLC the owner of 100 S. Adkins Way, in Meridian, Idaho. The building currently
has two tenants that occupy approximately 50% of the gross space. A construction company occupies
3,150 square feet and a classic car broker occupies 750 square feet. The remainder of the building was
previously occupied by the Idaho Division of Vocational Rehabilitation until it vacated the premises.
Long Dog acquired this property because it was "flex space", enabling Long Dog to have investment
income from the existing tenants while allowing Long Dog's members to utilize the space vacated by
Vocational Rehabilitation for their other business interests. The members of Long Dog are also the
principals in Ketlinski Law Office, PLLC. The members of Long Dog also have a collection of classic
vehicles that they desire to store in a single location. One of the members of Long Dog is a Certified
Functional Strength Coach who is starting a strength training and coaching business and the other is in
T.208-388.1000 251 E Front St,Suite 3rO
F-208.388.1001 PO Box 639
clarkwardle.com Boise ID 83701
Date:April 15, 2026
Page: 2
the preliminary stages of creating a new animal-related business that is a principal permitted use within
the zone, both of which could be operated jointly out of these premises.
To that end, Long Dog desires to initiate a remodel of the space to modify it from the office
configuration used by Vocational Rehabilitation to house all of Long Dog's members' business interests,
by converting three existing offices into warehouse and storage space accessible through the roll up
door, by creating a larger meeting space from two existing offices, and by including an additional
restroom replacing an office. Long Dog's proposed remodel of this portion of the building increases its
functionality as "flex space" and in fact makes it more compatible with the IL Zone, by facilitating uses
contemplated in the zone and reducing the amount of existing office space.
Due to that desire to remodel, Long Dog requested a building permit but was denied the ability to
remodel this property by Meridian Staff. This application was initiated to ensure that there was an
application appealable under the Local Land Use Planning Act, specifically, Idaho Code 67-6519; Idaho
Code 67-6521, and Idaho Code 67-6535, and a complete, supportive record of the City's actions.
Meridian Staffs denial of CZCU-2025-0002 is appealed for the following reasons:
• Requiring a certificate of zoning compliance to convert space that provided personal and
professional services to one that will provide personal and professional services violates the
takings clauses and the due process clauses of both the Idaho and United States Constitutions.
• Requiring a certificate of zoning compliance for a mere change in the user of property where the
use remains the same violates the takings clauses and the due process clauses of both the Idaho
and United States Constitutions.
• Denial of this application by Meridian Staff is an act that is arbitrary, capricious, and an abuse of
discretion.
• Denial of this application contravenes the intention of the Idaho legislature in its recent
enactment of S1326, the "Property Rights Protection Act", signed into law by Governor Little on
March 31, 2026, and effective upon its passage and approval.
In support of this appeal, we provide the following additional analysis.
B. Argument on Appeal
Long Dog seeks to modify space that has long been used for professional and personal services for the
personal commercial use of its members, through the conversion of the space to facilitate its members'
law office, vehicle storage, and potential training facility. There are no exterior modifications to the
property other than the construction of the proposed roll up door. The property was originally
approved for development and platted more than thirty years ago.
1. "Flex space" is the Use.
We note, that there has long been confusion on the part of Meridian Staff how "flex space" is intended
to function. That confusion appears rooted in the fact that there is an unwillingness in any zone to
Meridian Appeal Narrative-2
Date:April 15, 2026
Page: 3
acknowledge "flex space" as an actual use. The analysis that Meridian Staff has applied here ("When a
building includes multiple tenant spaces, however, the City analyzes each tenant space separately") is
wholly inconsistent with the plain language of the UDC and how"flex space" is intended to function.
"Flex space" is defined in Meridian City Code Section 11-12-1 as "the use of a building or a portion
thereof for small scale warehousing and/or light industry with associated office and/or retail showroom
space. Flexibility in the use of the interior spaces and low scale, attractive exterior appearance
characterize flex buildings." Thus, "flex space" is clearly defined as a distinct use that combines these
other elements. And the members of Long Dog's legal practice is associated with Long Dog's ownership
of the property, and use of other permitted or conditional uses as part of a multi tenant investment
property.
2. The Use, "Flex Space", is Subject to Specific Use Standards
Why do we note that"flex space" is the designated use? It is because Meridian City Code Section 11-4-1
reiterates that the purpose of the "Specific Use Standards" are as follows:
This chapter provides specific standards for all uses as set forth within
the applicable district in accord with chapter 2, "district regulations",
of this title.
Moreover, the Specific Use Standards have specified applicability to the entirety of"any property where
the specific use is listed" under Meridian City Code Section 11-4-2:
These regulations apply to any property where the specific use is listed
as a permitted, accessory, or conditional use in the tables of allowed
uses by district in accord with chapter 2, "district regulations", of this
title. It shall be unlawful and a violation of this title for any person to
use, construct, locate, initiate, alter, or maintain any structure, land or
real property, or cause any structure, land, or real property to be used,
constructed, located, initiated or maintained, in any manner which
violates, omits, or fails to conform to any procedure, standard or
requirement set forth in this chapter.
Meridian's Staff's premise by premise analysis is inconsistent with Meridian City Code and deprives
owners of"flex space" the value of their properties, by functionally prohibiting "flex space" as a use for
multi-tenant buildings.
3. Meridian is not Consistent in its Interpretation of its Code
Moreover, Meridian's recognition of the importance of "flex space" as such, was reiterated most
recently in the City of Meridian's adoption of Ordinance No. 25-2099. As implicitly acknowledged in
Ordinance No. 25-2099, once "flex space" is designated as the use, the user must also satisfy the specific
use standards found in Meridian City Code Section 11-4-3-18, which we restate here for convenience:
Meridian Appeal Narrative-3
Date:April 15, 2026
Page: 4
A. Office and/or retail showroom areas shall comprise a minimum of
thirty (30) percent of the structure and/or tenant space in the C-C
District, fifteen (15) percent in the C-G District, ten (10) percent in the
M-E District, and twenty(20) percent in the I-L and I-H Districts.
B. Light industry and warehousing shall not comprise more than seventy
(70) percent of the tenant space in the C-C District, seventy-five (75)
percent in the C-G and M-E Districts, and eighty (80) percent in the I-L
and I-H Districts.
C. In the C-C, C-G and M-E Districts, roll-up doors and loading docks shall
not be visible from a public street.
D. Retail use shall not exceed twenty-five (25) percent of leasable area
in any tenant space.
E. At a minimum, one (1) parking space shall be provided for every one
thousand (1,000) square feet of gross floor area.
If a "flex space" property complies with the specific requirements of Meridian City Code Section 11-4-3-
18, and the ratios of the uses set forth above, then the evaluation of what uses take place within the
"flex space", except for compliance with building codes and life safety requirements, ends. Meridian has
adopted ratios of use within the "flex space" use that are independent of the land uses that are
otherwise permitted. The individual tenant premises analysis Meridian Staff utilizes has no basis in
these specific use standards.
This interpretation is evidenced by Meridian City Code Table 11-213-2, the table of allowed uses within
commercial districts as well as Meridian City Code Table 11-2C-2, the table of allowed uses within
industrial districts.
First, the use "office" is not expressly identified in either Meridian City Code Table 11-213-2 or Meridian
City Code Table 11-2C-2. There are various uses which certainly necessitate offices therein, but in and
of itself, office is not a use that is specified as prohibited, permitted, accessory or conditional. Yet,
pursuant to Meridian City Code Section 11-4-3-18(A) there are specified minimums within "flex space"
for "office and/or retail showroom areas". In establishing the minimum of twenty(20) percent in the I-L
District, it is clear that office use and retail use are contemplated to be much more than merely an
accessory use within the I-L District as otherwise designated in Meridian City Code Table 11-2C-2.
Next, Meridian City Code Table 11-213-2 establishes that "Warehouse" is prohibited within the C-C
District and is authorized only as an accessory use within the C-G District. Moreover, pursuant to
Meridian City Code Table 11-213-2 the use "Industry, light" is also prohibited within the C-C District
while permitted with a conditional use permit in the C-G District. Notwithstanding those prohibitions,
we note that pursuant to Meridian City Code Section 11-4-3-18(B) that those two uses are actually
permitted within either of the C-C District or the C-G districts up to 70% and 75% of the "tenant space"
respectively when "flex space". In this instance, "associated" as cited by Meridian Staff in the definition
Meridian Appeal Narrative-4
Date:April 15, 2026
Page: 5
of "flex space" is doing significant work since the "associated" uses are neither permitted, nor
conditional, nor accessory. The uses that Long Dog proposes for its property are in fact either
permitted, or conditional, or accessory.
Thus, we see that because "flex use" is the use, other than satisfaction of the amendments to Meridian
City Code Section 11-4-3-18, further evaluation of additional uses within in the structure are irrelevant.
Nothing in these recent amendments support the notion articulated in Meridian Staff's denial of this
request that for a multi tenant building the City is to analyze each space distinctly and divorced from the
facts underlying the proposed "flex space" use.
4. Meridian is not Consistent in its Enforcement of its Code
We have repeatedly heard Meridian Staff claim that they merely seek to preserve the IL Light Industrial
Zone for light industrial uses as the rationale for why certain other commercial uses have been excluded,
Meridian's economic base requires buildings in the IL Zone, and that is why Meridian Staff is so
protective in its interpretation of the UDC.
However, that belief is far from reality.
Meridian has repeatedly and willingly granted conditional use permits for recreational and personal
services within the IL Zone, without any of the concerns articulated about the impact that it has upon
the stock of"flex space" within the IL Zone. Among these most recent grants of conditional use permits
for recreation and personal service uses by the City of Meridian are the following:
• K1 Speed CUP H-2021-0077
• Black Box VR CUP H-2023-0022
• Daily Fit Bod CUP H 2O23-0060
• The Base Jiu Jitsu CUP H 2O23-0032
• Treasure Valley Athletic Center MCU-2024-0003
• Elite Fitness CUP H-2025-0021
• Uplifted Gym CUP-1-12O25-0023
• The Tee Box CUP H-2025-0056
We acknowledge that Meridian Staff will respond "but indoor recreation is a conditional use", which it
is. But in reviewing the staff reports and the decisions adopted in the approval of those conditional use
permits, neither the planning and zoning commission nor the city council have ever adopted the analysis
and process that Meridian Staff has articulated with respect to office uses that desire the flexibility
afforded by"flex space".
Meridian Appeal Narrative-5
Date:April 15, 2026
Page: 6
The concern articulated by Meridian Staff, however, is further belied by the lack of enforcement of
professional and personal service office prohibitions within the IL Zone. Various other service office
uses have been allowed to exist throughout the IL Zone in Meridian, including:
• Land Use Solutions—231 E. 51"Street
• Farmer's Insurance—226 E 5t"Street
• Assurity Drug and Alcohol Testing—480 E. Frankling Road, Suite 102
• Idaho Horse Rescue—890 E Franklin Road, Suite 202
The foregoing is not an exhaustive list of conditional uses allowed within the IL Zone, nor an attempt to
compel existing commercial uses to be curtailed. The foregoing are offered as evidence of the arbitrary
and inconsistent manner in which Meridian Staff has applied the relevant code.
The rise of "flex space" as a use and the City's expansion of its permissibility to additional zones, has
corresponded to the fundamental recognition that truly mixed use commercial spaces are necessary in
today's economy. The rigid notions of Euclidian Zoning have been abandoned by many jurisdictions,
including Meridian, in the embrace of mixed use development.
Certainly, at the time of those evaluations, Meridian Staff lacked the benefit of the 2025 amendments
to Meridian City Code Section 11-4-3-18. By acknowledging that a minimum amount of office or retail
activity is required in "flex space" even in zones that otherwise limit them to being accessory uses, and
that warehousing activities are permitted "flex space" activities within zones that clearly prohibit it, it is
clear that the City Council has determined that the analysis of "flex space" begins and ends with the
building as a whole and that Meridian Staff's ongoing retreat into the depths of the Meridian City Code
to do a secondary evaluation of the use is erroneous.
It does not seem plausible, especially in light of the City Council's 2025 amendments to Meridian City
Code Section 11-4-3-18, that the City of Meridian seeks to punish so many small businesses and small
property owners with unreasonable and uneven enforcement of its code regarding "flex space",
especially in older properties like this one that have had several cycles of diverse tenants. The uneven
nature of enforcement of limitations on office uses within "flex space" is evident from our review of
similarly zoned and developed properties throughout Meridian.
C. Conclusion
Long Dog purchased this property because it would permit its members to consolidate all of their
desired professional and personal uses in a single location. They know the neighboring uses, they know
the tenants that they have and desire to maintain. They selected this property exactly because it was
permitted "flex space" and do not desire to materially modify the use, rather they seek to make the
space more compliant with "flex space"through its renovation.
Consistent with the foregoing and this application, on behalf of our clients we respectfully request the
following:
Meridian Appeal Narrative-6
Date:April 15, 2026
Page: 7
• Approval of a Certificate of Zoning Compliance requested above for Long Dog,
LLC.
• Approval of the site plan that it has proposed to facilitate its intended leases for
the space.
• Authorization to proceed to obtain a building permit for those improvements.
• Additionally, the City should amend its ordinances so that office uses that seek
the ability to have "flex space" elements, i.e. storage, warehousing, roll up
doors and the like, are permitted as a conditional use, just like gyms, training
facilities, dance studios, and martial arts studios.
We look forward to this matter being heard by the City Council.
Sincerely,
AA)
----
Geoffrey M. Wardle
Meridian Appeal Narrative-7
Application Narrative
DEVELOPMENT REAL PROPERTY ZONING
CLARK
WARDLE
Geoffrey M.Wardle
(208) 388-3321
gwardle@clarkwardle.com
Via Citizen Access Portal Submission
March 25, 2026
City of Meridian
Community Development
Planning Division
33 E Broadway Ave
Suite 102
Meridian, ID 83642
RE: Long Dog, LLC—100 5 Adkins
CW File#: 24446.1
City of Meridian:
We represent Long Dog, LLC, the owner of 100 S. Adkins Way, in Meridian, Idaho. 100 S. Adkins is a
multitenant flex building that has a gross area of approximately 8,400 square feet.
A. Background
The property has been zoned I-L Light Industrial since its original annexation into the City of Meridian in
1997 with the development of the Medimont Subdivision. The building has been and continues to be
utilized as "flex space". It has all of the indicia of flex space.
The building currently has two tenants that occupy approximately 50%of the gross space. A construction
company occupies 3,150 square feet and a classic car broker occupies 750 square feet. The remainder of
the building was previously occupied by the Idaho Division of Vocational Rehabilitation until it vacated the
premises.
In addition to the leasing of the premises to these existing tenants, the principals of Long Dog, LLC, have
certain additional business interests that they own and desire to operate from the property as tenants of
Long Dog, LLC, including their personal offices of Ketlinski & Ketlinski and personal vehicle warehouse
storage. As the owner of the building, Long Dog's principals derive the benefit and value of it as an
investment property leasing portions to others, as well as for their own permitted purposes within "flex
T.208-388.1000 251 E Front St,Suite 3rO
F-208.388.1001 PO Box 639
clarkwardle.com Boise ID 83701
Date: March 25, 2026
Page: 2
space," and further desire to operate the principals private offices from the property. That is the essence
of"flex space", as further described and discussed below.
To that end, they desire to initiate a remodel of the space to reconfigure it from the manner in which
Vocational Rehabilitation utilized it, to add certain additional facilities and spaces, incorporate a roll up
door, and make other improvements. An initial schematic of this proposed renovation is depicted in
Exhibit A attached hereto, and incorporated herein for reference.
B. Application Request and Legal Standards
It is our understanding from our clients' initial communication with the City of Meridian that they have
been informed that professional services cannot be performed within "flex space" in the IL District. We
believe that this is an incorrect interpretation of the code, especially based on the recent actions of the
City Council. To ensure that the City of Meridian has a fully developed request before it, we make this
application for a Certificate of Zoning Compliance, pursuant to Section 11-513-1. We note that there are
no modifications proposed to the property, other than the construction of the proposed roll up door, and
the interior remodel. The property was originally approved for development and platted, more than thirty
years ago. As to this property, except as noted above, there are no exterior modifications to the
landscaping, parking lot, lighting or other exterior elements of the existing structure. As such, in reviewing
the Certificate of Zoning Compliance checklist, various elements are not provided as there is no exterior
change to the property, other than the installation of the roll up door. As such, It does not appear that
there is a need for Trash Enclosure Approval; a Photometric Plat, Landscape Plan, Elevations, Autocad
Files, or Public Utility Plan, as none of the identified work implicates or necessitates modification of the
previously approved documents associated with the original construction of the building.
1. "Flex space" is the Use.
We note,that there has long been confusion on the part of Meridian Staff how"flex space" is intended to
function. That confusion appears rooted in the fact that there is an unwillingness in any zone to
acknowledge "flex space" as an actual use. It is.
"Flex space" is defined in Meridian City Code Section 11-12-1 as"the use of a building or a portion thereof
for small scale warehousing and/or light industry with associated office and/or retail showroom space.
Flexibility in the use of the interior spaces and low scale, attractive exterior appearance characterize flex
buildings." Thus, "flex space" is clearly defined as a distinct use that combines these other elements.
2. The Use, "Flex Space", is Subject to Specific Use Standards
Why do we note that"flex space" is the designated use? It is because Meridian City Code Section 11-4-1
reiterates that the purpose of the "Specific Use Standards" are as follows:
This chapter provides specific standards for all uses as set forth within the
applicable district in accord with chapter 2, "district regulations", of this title.
Moreover, the Specific Use Standards have specified applicability to the entirety of"any property where
the specific use is listed" under Meridian City Code Section 11-4-2:
Date: March 25, 2026
Page: 3
These regulations apply to any property where the specific use is listed as a
permitted, accessory, or conditional use in the tables of allowed uses by district
in accord with chapter 2, "district regulations", of this title. It shall be unlawful
and a violation of this title for any person to use, construct, locate, initiate, alter,
or maintain any structure, land or real property, or cause any structure, land, or
real property to be used, constructed, located, initiated or maintained, in any
manner which violates, omits, or fails to conform to any procedure, standard or
requirement set forth in this chapter.
3. The Use Specific Standards for"Flex Space" Reaffirm it as the Use.
As a specified use, the importance of "flex space" as a such, was reiterated most recently in the City of
Meridian's adoption of Ordinance No. 25-2099. As implicitly acknowledged in Ordinance No. 25-2099,
once "flex place" is designated as the use, the user must also satisfy the specific use standards found in
Meridian City Code Section 11-4-3-18,which we restate here for convenience:
A. Office and/or retail showroom areas shall comprise a minimum of
thirty(30)percent of the structure and/or tenant space in the C-C District,
fifteen (15) percent in the C-G District, ten (10) percent in the WE
District, and twenty(20) percent in the I-L and I-H Districts.
B. Light industry and warehousing shall not comprise more than seventy
(70) percent of the tenant space in the C-C District, seventy-five (75)
percent in the C-G and WE Districts,and eighty(80) percent in the I-L and
1-H Districts.
C. In the C-C, C-G and WE Districts, roll-up doors and loading docks shall
not be visible from a public street.
D. Retail use shall not exceed twenty-five (25) percent of leasable area in
any tenant space.
E. At a minimum, one (1) parking space shall be provided for every one
thousand (1,000) square feet of gross floor area.
If a "flex space" property complies with the specific requirements of Meridian City Code Section 11-4-3-
18, and the ratios of the uses set forth above, then the evaluation of what uses take place within the flex
space,except for compliance with building codes and life safety requirements end. Meridian has adopted
ratios of use within the "flex space" use that are independent of the land uses that are otherwise
permitted.
This interpretation is evidenced by Meridian City Code Table 11-213-2, the table of allowed uses within
commercial districts as well as Meridian City Code Table 11-2C-2, the table of allowed uses within
industrial districts.
Date: March 25, 2026
Page: 4
First, the use "office" is not expressly identified in either Meridian City Code Table 11-213-2 or Meridian
City Code Table 11-2C-2. There are various uses which certainly necessitate offices therein, but in and
of itself, office is not a use that is specified as prohibited, permitted, accessor or conditional. Yet,
pursuant to Meridian City Code Section 11-4-3-18(A) there are specified minimums within "flex space"
for "office and/or retail showroom areas". In establishing the minimum of twenty(20) percent in the I-L
District, it is clear that office use and retail use are contemplated to be much more than merely an
accessory use within the I-L District as otherwise designated in Meridian City Code Table 11-2C-2.
Next, although Meridian City Code Table 11-213-2 demonstrates that "Warehouse" is prohibited within
the C-C District and is authorized only as an accessory use within the C-G District. Moreover, pursuant to
Meridian City Code Table 11-213-2 the use "Industry, light" is also prohibited within the C-C District while
permitted with a conditional use permit in the C-G District. Notwithstanding those prohibitions, we
note that pursuant to Meridian City Code Section 11-4-3-18(B)that those two uses are actually permitted
within either of the C-C District or the C-G districts up to 70%and 75%of the "tenant space" respectively
when "flex space".
Thus, we see that because "flex use" is the use, other than satisfaction of the amendments to Meridian
City Code Section 11-4-3-18, further evaluation of additional uses within in the structure are irrelevant.
4. Historic Custom and Practice is Inconsistent with Meridian City Code as Amended.
As noted above, our client has been informed that its request to utilize a portion of 100 S.Adkins Way for
the provision of professional services, in addition to the existing tenancies, is not permitted as "flex
space." In preparation of this application we have reviewed and evaluated certain prior applications that
have been initiated.
In April 2023, an application for tenant improvements at 50 S. Adkins, next door to this property was
initiated for office and storage space for a professional surveyor. The communication among the applicant
and Meridian Staff is attached as Exhibit B. Although Meridian Staff acknowledged that the space was
"flex space" and did comply with the then-existing "specific use standards," it rejected the application
because it "appears to be only office space." Staff did so, invoking the "North American Industry
Classification System".
However, this appears to be a misapplication of Meridian City Code Section 11-1-5(E), regarding the
interpretation of the code,which provides as follows:
Allowed uses. If a proposed use of property is not specifically listed in
chapter 2, "district regulations", of this title,the use shall be prohibited,
except as follows: The director may determine that a proposed use not
listed in chapter 2, "district regulations", of this title, is equivalent to a
principal permitted or conditional use. In making the determination,the
Director shall consider the following:
Date: March 25, 2026
Page: 5
1. The impacts on public services and activities associated with the
proposed use are substantially similar to those of one(1)or more of the
uses listed in the applicable base districts as allowed;
2. The proposed use shall not involve a higher level of activity or density
than one (1) or more of the uses listed in the applicable base districts
as allowed;
3. The proposed use is within the same three (3) digit category of an
allowed use listed in the latest edition of the "North American Industrial
Classification System (NAIC)", published by the United States
Department of Commerce;
4. The proposed use is consistent with the purpose of the district in
which the use is proposed to be located; and
5. The proposed use is in substantial conformance with goals and
objectives of the comprehensive plan.
As noted therein,analysis of the"North American Industry Classification System" is but one of five factors
that the "Director shall consider." Even after acknowledging that the proposed surveyor use was part of
a "flex space" building and with the elements associated with professional surveying, Meridian Staff
clearly invoked Meridian City Code Section 11-1-5(E)(3) without conducting the full, mandatory analysis.
Similarly, in the same building 50 S. Adkin in 2024, a request was raised regarding the ability of a
property management company to occupy space with its office and the remainder utilized for storage
supporting its operations. The communication among the applicant Meridian Staff is attached as Exhibit
C. Again, rather than focusing on the existence and status of the building as"flex space" and the inherent
nature of the proposed use as "flex space", Meridian staff went through an unnecessarily convoluted,
even if ultimately positive determination, that yes, a property management company was permitted to
operate within "flex space" deeming it to be "warehouse."
Certainly, at the time of those evaluations, Meridian Staff lacked the benefit of the 2025 amendments
to Meridian City Code Section 11-4-3-18. By acknowledging that a minimum amount of office or retail
activity is required in "flex space" even in zones that otherwise limit them to being accessory uses, and
that warehousing activities are permitted "flex space" activities within zones that clearly prohibit it, it is
clear that the City Council has determined that the analysis of "flex space" begins and ends with the
building as a whole and that Meridian Staff's ongoing retreat into the depths of the Meridian City Code to
do a secondary evaluation of the use is erroneous.
It does not seem plausible,especially in light of the City Council's 2025 amendments to Meridian City Code
Section 11-4-3-18,that the City of Meridian seeks to punish so many small businesses and small property
owners with unreasonable and uneven enforcement of its code regarding"flex space", especially in older
properties like this one that have had several cycles of diverse tenants. The uneven nature of enforcement
Date: March 2S, 2026
Page: 6
of limitations on office uses within "flex space" is evident from our review of similarly zoned and
developed properties throughout Meridian.
C. Conclusion.
Consistent with the foregoing and this application, on behalf of our clients we respectfully request the
following:
• Approval of a Certificate of Zoning Compliance requested above for Long Dog,
LLC.
• Approval of the site plan that it has proposed to facilitate its intended leases for
the space.
• Authorization to proceed to obtain a building permit for those improvements.
If Meridian Staff is unable or unwilling to do so,then we request a final written decision on this matter as
soon as practicable so that we may proceed with an appeal to the Meridian City Council.
In support of this Application we provide the following additional documents:
• Application for Certificate of Zoning Compliance and supporting materials
• Exhibit A—Proposed site plan for a portion of 100 S. Adkins
• Exhibit 6—April 2023 Correspondence
• Exhibit C—October 2024 Correspondence
Please let me know if you have any further questions or concerns.
Sincerely,
4
Geoffrey M. Wardle
cc: Client
Stacy Hersch, shersh@meridiancity.org
Paula Middleton, pmiddleton@meridiancity.org
Exhibit A
Proposed Site Plan
D_
O
o
lz7
d
r
"d
z
�N On r - - moo
------------------
H` O
O
-----------------
F 7
O
L
om o
EnT o 0
o Dy .D On DAT o
A
COPYRIGHT O Arch,Rk 2025 DRAWINGS MAY NOT BE REUSED WITHOUT THE WRITTEN PERMISSION OF THE ARCHITECT
lj �.wME Ilc,Arch, DNA- A Flex Space Tenant Improvement for A p
ro ' Long Dog LLC Architecture+Planning (�
° 537 E.Forest Ridge Drive
D Meridian,ID Meridian,Idaho 83642 S
(208)921.0754
Exhibit B
April 2023 Correspondence
From: Julia Garofalo on behalf of Julia Garofalo<iaarofalo(d)meridiancitv.ora>
To: Chris Anderson
Cc: Nick Napoli; Bill Parsons; Keoan Aman
Subject: RE:C-TI-2023-0046
Date: Tuesday,April 11,2023 10:54:20 AM
Attachments: irnaae002.Dna
Hey Chris,
I understand that we approved this space as a Flex Building, under permit C-SHELL-2021-0019, but
when we approved this building it showed space for 5 tenants therefore the proposed use that
moves into that space must comply with the allowed uses chart. As explained previously, the North
American Industry Classification System (NAICS), explains the use and how it would be classified in
our code.
Thank you,
Julia Garofalo I Assistant Planner
City of Meridian I Community Development
33 E. Broadway Ave., Meridian, Idaho 83642
Phone: (208) 489-0601
tfE IT�
Built for Business, Designed for Living
All e-mail messages sent to or received by City of Meridian e-mail accounts are subject to the Idaho law,
in regards to both release and retention, and may be released upon request unless exempt from disclosure by law.
From: Chris Anderson <canderson@rudeenarchitects.com>
Sent:Tuesday, April 11, 2023 9:53 AM
To:Julia Garofalo<jgarofalo@meridiancity.org>
Cc: Nick Napoli <nnapoli@meridiancity.org>; Bill Parsons<bparsons@meridiancity.org>; Kegan
Aman <kaman@meridiancity.org>
Subject: RE: C-TI-2023-0046
External Sender-Please use caution with links or attachments.
Julia,
It is listed as a 'A', which indicates that it is an approved use as an accessory space. This tenant
occupies approximately 20% of the entire building, so it could be looked at as an accessory space to
the building as a whole. According to 11-2C-2A, it defines the types of business that are promoted
to be allowed in a light industrial area:
Light industrial district(I-Q. The purpose of the I-L district is to provide for convenient employment
centers of light manufacturing, research and development, warehousing, and distributing. In
accord with the Meridian Comprehensive Plan, the I-L district is intended to encourage the
development of industrial uses that are clean, quiet and free of hazardous or objectionable
elements and that are operated, entirely, or almost entirely, within enclosed structures.
Accessibility to transportation systems is a requirement of this district.
Could we make the argument that survey engineers research information at a site and then develop
solutions for the problems identified at the site. I am just trying to look at the intent of the code to
see if this business can be a fit for the district. If we look at surrounding businesses that were
allowed in the I-L district, within a block from 50 Adkins Way, at 149 Adkins Way there is PermaCold
Engineering, listed as engineering consultants and 100 Adkins Way is Mechanical Drafting Services.
Both of these are similar business types that set a precedence in the area. Please let me know the
process in which the engineering consultants and drafting services went through to obtain a permit
and we would like to use the same procedure. Thank you once again for your time and your help.
Christopher T.Anderson
Project Manager
Rudeen Architects
Tel:+208.338.1413 Ext. 104
Direct:+208.954.8753
Email:canderson(@rudeenarchitects.com
"When you abandon freedom to achieve security,you lose both and deserve neither"Thomas Jefferson
From:Julia Garofalo< arofalo(@meridiancity.org>
Sent:Tuesday, April 11, 2023 9:11 AM
To: Chris Anderson <candersonCo)rudeenarchitects.com>
Cc: Nick Napoli <nnapoli(@meridiancity.org>; Bill Parsons<boarsons(@meridiancity.org>; Kegan
Aman <kaman(@meridiancity.org>
Subject: RE: C-TI-2023-0046
Hello,
If the use was allowed with a Conditional Use permit approval, it would be listed with a 'C' on the
following chart. Please read through Article C.— Industrial Districts, information which I have linked
below.
11-2C-2 Industrial Districts, Allowed Uses
https://library.municode.com/id/meridian/codes/code_of ordinances?
nodeld=TIT1IUNDECO CH2DIRE ARTCINDI 11-2C-2ALUS
Thank you,
Julia Garofalo I Assistant Planner
City of Meridian I Community Development
33 E. Broadway Ave., Meridian, Idaho 83642
Phone: (208) 489-0601
C4fE ID�
Built for Business, Designed for Living
All e-mail messages sent to or received by City of Meridian e-mail accounts are subject to the Idaho law,
in regards to both release and retention,and may be released upon request, unless exempt from disclosure by law.
From:Julia Garofalo
Sent:Tuesday,April 11, 2023 8:46 AM
To: 'canderson@rudeenarchitects.com' <canderson(@rudeenarchitects.com>
Cc: Nick Napoli <nnapoli(@meridiancity.org>; Bill Parsons<baarsons(@meridiancity.org>; Kegan
Aman <kaman(@meridiancity.org>
Subject: RE: C-TI-2023-0046
Hello,
As mentioned on our call yesterday, I needed some time to look into what surveying would be
classified as. The North American Industry Classification System (NAICS) states that this use is also
known as, Geophysical Surveying and Mapping Services. Which falls under the category Professional.
Scientific. and Technical Services. So, unfortunately, in Meridian City code that translates to a
professional service, which is only allowed as an Accessory Use in the I-L zone. We won't be able to
move forward with your C-TI pending building permit at this time. Please let us know if you have any
questions or further explanation.
Thank you,
Julia Garofalo I Assistant Planner
City of Meridian I Community Development
33 E. Broadway Ave., Meridian, Idaho 83642
Phone: (208)489-0601
�rE I DIAN
Built for Business, Designed for Living
All e-mail messages sent to or received by City of Meridian e-mail accounts are subject to the Idaho law,
in regards to both release and retention,and may be released upon request, unless exempt from disclosure by law.
From: Bill Parsons<bparsons(d)meridiancity.org>
Sent: Monday, April 10, 2023 4:21 PM
To:Julia Garofalo<igarofalo(@meridiancity.org>
Cc: Nick Napoli <nnapoli(@meridiancit)1.org>
Subject: RE: C-TI-2023-0046
I would go to NAICS and see how a surveyor's office is classified.
Bill Parsons,AICP I Planning Supervisor
City of Meridian I Community Development Dept.
33 E. Broadway Ave., Ste. 102, Meridian, Idaho 83642
Phone: 208-884-5533 1 Direct: 208-489-0571
4 E ID
Built for Business, Designed for Living
All e-mail messages sent to or received by City of Meridian e-mail accounts are subject to the Idaho law,
in regards to both release and retention, and may be released upon request unless exempt from disclosure by law.
From: Nick Napoli <nnapoli(@meridiancity.org>
Sent: Monday, April 10, 2023 4:21 PM
To:Julia Garofalo<'garofalo(@meridiancity.org>; Bill Parsons<baarsons(@meridiancity.org>
Subject: RE: C-TI-2023-0046
H i,
While this does meet the requirements for Flex Space in the specific use standards, I don't think it
actually is being used as a flex space.This appears to be only office space which is an accessory use
in I-L. I think we may to tell them to find a new site.
From:Julia Garofalo
Sent: Monday, April 10, 2023 3:24 PM
To: Bill Parsons <baarsonsl@meridiancity.org>
Cc: Nick Napoli <nnapoli(@meridiancity.org>
Subject: C-TI-2023-0046
Hello,
I need a second opinion. This tenant improvement came through last week in a permitted flex space
building at 50 S. Adkins Way and the proposed plans appear to be a professional service with
accessory storage, however, the applicant is stating that it is more of a dispatch center (11-4-3-45)
for surveyors, and the office space would be more or less the secondary use because the majority of
the time their staff is working in the field. With that, if I have him file a change of use application for
a dispatch center would you agree that this is the primary use?They wouldn't necessarily have fleet
vehicles, but employees would use their own vehicles and pick up the surveying equipment from the
property. Here is the floor plan submitted with his C-TI application:
WAN SrTRANGE
— � — ICE®In"
m
�+
H
4 2 <i #
OFF LE
u
L*F LE
c �
ru
� e
o�
s
F ❑
2
I I �
I I i
E I MEN I
I ® I
I I
I I FIALL
i Iit�
— I I
I IlY;)MLN I
1�= I U. max
I I
I I
0 �
SIOPA; L
Ia
C
Thank you,
Julia Garofalo Assistant Planner
City of Meridian I Community Development
33 E. Broadway Ave., Meridian, Idaho 83642
Phone: (208) 489-0601
Built for Business, Designed for Living
All e-mail messages sent to or received by City of Meridian e-mail accounts are subject to the Idaho law,
in regards to both release and retention, and may be released upon request unless exempt from disclosure by law.
Exhibit C
October 2024 Correspondence
Fran: Sttie't'rTh on beha'of Stan I sM1ersM1lmmertla
rnh=A.ne
sagax: a so s eaune way smte 10
Date: nonaay,oaaber 21,20249:o):09 PM
Atbch_
Hi Chris,
Prepare the plans for the building department.
Thank you,
Stacy Hersh i Associate Planner
City of Meridian I Community Development Department
33 E.Broadway Ave.,Meridian,Idaho 83642
Phhonne�(208)-489-0576,Fax:(208)-887-1297
C/}I DIAN
Built for Business,Designed for Living
All a-mail messpgessent[o or rereived by Gty of Meridian a-mail accounts are suby-[o[he Idaho law,
regards t0 b0th release end retention,and maybe released upon regve,,unless exemptfrom disclosure bylaw.
From:Chris Anderson<cnderson@rudeenarchitects.com>
Sent:Monday,October 21,20248:45 AM
To:Stacy Hersh<shersh@mendiancry.org>
Subject:RE:50 S Adkins Way Suite 140
Extemal Sender-Please use caution with links or attachments.
Thankyou Stacyl I appreciate your help in identifying the use.Do l need to submit anything to Planning&Zoning or just prepare the plans to go directly to the Building Department for a permit?
Christopher T.Anderson
RudeenAmh u—
Te1:+208.336.1413 Ext IN
D re ct'.1208.954.8753
Email.candersonrarudeenarch"tectz com
"When you abandon freedom to achieve security.you lase both and deserve neither'Thomas lejJerson
From:Stacy Hersh«hershnc meridianciNlq>
Sent:Friday,October 18,2024 4:47 PM
To:Chris Anderson<candersonPrudeenarchitects.com>
Subject:RE:50 S Adkins Way Suite 140
Then the use would be warehouse.
Stacy Hersh i Associate Planner
City of Meridian I Community Development Department
33 E.Broadway Ave.,Meridian,Idaho 83642
Phone:(208)-489-0576,Fax:(208)-887-1297
Built for Business,Designed for Living
All a-mail messages sent[o or rereived by City of Meridian a-mail .nn are subject to the Idaho law,
m regards m both release and retention,and may be released upon request,unless exemptfiom disclosure bylaw.
From:Chris Andersonander aorta mdeen rr:hiter:tS cnm>
Sent:Friday,October 18,2024s3:48 PM
To:Stacy Hersh<shershOmeridiancitv.on,
Subject:RE:50 S Adkins Way Suite 140
External Senaer-Pill use caution with links or attachments.
Stacy,
There will be no company vehicles.
Christopher T.Anderson
Rvdeen Architetts
e1:1208.338.1413 EA,104
tt:+208.954.8753
Email:rander rrh'te
"when you abandon freedommachieve security,you lose both and deserve neither"Thomasltr v,
From:Stacy Hersh<shershOmer dianc'N or
Sent:Friday,October 18,20243:38 PM
To:Chris Anderson ander on crtnidecn rchiter:tc com>
Subject:RE:50 S Adkins Way Suite 140 a
Hi Chris,
It sounds like warehousing with the dispatching of services to locations to repair/clean.Will there be company vehicles?These are permitted uses but will require a QC Change of Use.
11-4-3-45.-Dispatch center for mobile services. % ® e
A. No outdoor storage of material shall be al lowed.All materials shall be stored indoors.
B. Adequate off-street area shall be provided forfleetvehicle storage.
1. Fleet vehicle storage shall only be on surfaces composed of one(1)of the following materials:concrete,asphalt,grasscrete,pavers,bricks,macadam,or recycled asphalt.
2. Fleet vehicle storage shall not block sidewalks or parking areas and may not impede vehicular or pedestrian traffic.
3. Fleet vehicle storage shall be screened with a six-foot sight obscuring fence,or fleet vehicle storage shall be designed as an off street parking area consistent with the standards as set forth in
sections 11-3C-5 and 11-3B-8 of this title.
C. The site shall not be used as a"contractor's yard"as herein defined.
D. The site shall not be used as a"vehicle wrecking erjunk yard"as herein defined.
E. The site shall not be used as a"terminal,freight or truck"as herein defined.
(Ord.11-1494,9-6-2011,eff.9-12-2011)
Thanks,
Stacy Hersh I Associate Planner
City of Meridian I Community Development Department
33 E.Broadway Ave.,Meridian,Idaho 83642
Phhone:(208)-489-0576,Fax:(208)-887-1297
Cn DIAN
Built for Business,Designed for Living
All a-mail messagessent to orrereived by City of Meridian e-mailacroants are subjer[m[he Idaho law,
,n regards to both release and retention,and may be released upon request,unless exemptfrom disclosure bylaw.
From:Chris Andersonantler onita mdeen rchitects cnm>
Sent:Friday,October 18,2024s3:25 PM
To:Stacy Hersh<shersh(dmeridiancity.ore>
Subject:RE:50 S Adkins Way Suite 140
Extemal Sender-Please use caution with links or attachments.
Stacy,
The warehouse space will actually be storage,for cleaning supplies and construction supplies;to take care of and maintain properties that they have invested in.I would argue that it is similar to a construction yard,because they will have
building material like plumbing,electrical,hardware,and finishes.They will also be similar to a mobile cleaning service,and store cleaning supplies back there.Based on the chart,I am not sure how to classify the space,so I was hoping to
getycurinput.Please let me know if this answers your question.
Christopher T.Anderson
Rudeen ArchiteRs
Tel:+208.338.1413 Ed,104
pirect'.120B.954.8753
Email,candersonlarudeenarcM"tectz com
^when you abandon freedom to aehleye......h,you loan both ana daa—neld,ar°Th.—ezft—
From:Stacy Hersh<shersh r)o me ridiancity.ore>
Sent:Friday,October 18,2024 3:14 PM
To:Chris Anderson<cndersonrdrudeenarchitects.com>
Subject:RE:50 5 Adkins Way Suite 140
Hi Chris,
What is the type of use proposed in the warehouse space?
Thank you,
Stacy Hersh I Associate Planner
City of Meridian I Community Deyelo p—t Department
33 E.Broadway Ave.,Meridian,Idaho 83642
Phone:(208)-489-0576,Fax:(208)-887-1297
L/yt DIAN
Built for Business,Designed for Living
All,-mail messages sent to or—wi d by City fMeridian a-mail acroants are subject to the Idaho law,
,n regards to both release and retention,and may be releasetl upon request,unless exemptfrom disclosure bylaw.
From:Chris Andersonantler onraa rndeen rchitects com>
Sent:Friday,October 18,2024s1:S5 PM
To:Stacy Hersh<shershrameric iandt fora,
Subject:50 5 Adkins Way Suite 140
External sender-Please use caution with links or attachments.
Stacy,
A property management company would like to lease Suite 140 at 50 S Adkins Way and I would like to know if this will be an acceptable use in that zone,before I move forward with the Construction Documents.Attached is a PDF of the
floor plan.The front office is less than 25%of the tenant space and the remaining area will be used for storage of the cleaning and construction supplies.Please feel free to contact me if you have any questions.Thank you for your time
and your help!
Christopher T.Anderson
Rudeen AmhiteRs
Tel:+Eca.—A40 EM.104
n [:+208.9548753
Ema il.candersor—deenarch.-1-om
^when you abandon freedom to achieve security,you loss both ana deserve nelmer"Thomoslejfe,—
Affidavit of Legal Interest
AFFIDAVIT OF LEGAL INTEREST
I, TY A. KETLINSKI, as manager of Long Dog, LLC, 2586 E.Autumn Way, Meridian, Idaho,
being first duly sworn upon, oath, depose and say:
1. That Long Dog, LLC, is the record owner of the property described on the attached, and
it grants permission to:
Geoffrey Wardle, Clark Wardle LLP, 251 E.Front Street, Suite 310, Boise Idaho
to submit the accompanying application pertaining to that property.
2. 1 agree to indemnify, defend, and hold the City of Meridian and its employees harmless
from any claim or liability resulting from any dispute as to the statements contained
herein or as to the ownership of the property which is the subject of the application.
3. I hereby grant permission to City of Meridian staff to enter the subject property for the
purpose of site inspections related to processing said application.
Dated: March 19, 2026
WK104z�
Ty A. Ketlinski, M ager
SUBSCRIBED AND SWORN to before me the day and year first above written.
STATE OF IDAHO
ss.
COUNTY OF ADA
This record was acknowledged before me on March 19, 2026,by Ty A.,nKe'tlinski
(seal) M.ANNE VOSS l/'✓l� oc"�-
COMMISSION*20252818 Notary Public
NOTARY PUBLIC My Commission Expires: July 14,2031
STATE OF IDAHO
MY COMMISSION EXPIRES 07/14/2031
Recorded Plat
PLAT SHOWING
"TNT,IONT SUBDIVISION No. I
A PORTION OF THE NE i/4,NE 1/4,SECTION 18
TOWNSHIP 3 NORTH,RANGE 1 EAST,
BOISE MERIDIAN
MERIDIAN, ADA COUNTY, IDAHO
BASIS OF BEARINGS UNPLATTED Nk� 1997
OL E. FRANKLIN ROAD Pam CP@F 9377495�
s 6916'18-w 7 8 LEGEND
7 S 89'46'18"W S 89'48'18"W_ _ 848.40' - � _
g 1327.70' n -- -526.87'N 89'46 - E --�847.60' 31953'- - 4e11:70 18 17 & Found Brass Cap Monument
NW Comr `�•t ^lam
NE t/4 NW Coma 466.84' 263.68 SF Oo 19 Found Aluminum Cap
CP&F 9500/4 NE 1/4 NE 1/4 S B9'46'18"W 1 468.27' �� N 89'48'18'E 1 28.11, Vl O Found 5 8 Iron Pin
Section 18 'p /"
CP$F 96005808 -------._._ .. _. _ __ _ 29'
ITg 247.37' 220.90' -i w' _ _- 248.10' 20.OT=',I la1 ,y • Set 5/8"x 30"Iron Pin with Plastic Cap
t 'ACCESS RESTRICTION I �IWa m • Set 1/2"x 24" Iron Pin with Plastic Cop
20'LANDSCAPING w �I SEE NOTE 10 .IW
1 �^ 'D1 ® Set 2" x 36" Pipe
SETBACK to 3 �.I m REAL POINT OF BEGINNING REAL POINT OF BEGINNING(INITIAL POINT)
8 I (INITIAL POINT MONUMENT)
O p 3 g 2 N . ^10'WIDE IRRIGATION PIPE Boundary Line
i oml EASEMENT FOR THE BENEFIT Lot Line
..ppI • OF THE MEDIMONT SUBDI�1510N lr I Centerline of Street
�I I nl BUSINESS OWNERS ASSOCIATION m I ----------
AND DOWNSTREAM WATER USERS N Utility, Drainage and Irrigation Easement Line
L8 L7 I S 89'01'17"E I
5&00.1O CL F PIPER CT iT 281.00'
NOTES
790.17, I 1. Building setbacks and dimensional standards in this subdivision shall be in
I N 89V7'17 W n + _N 89•01'17"W r �g o' JL compliance with the applicable zoning regulations of the City of Meridian,
r Idaho.
216.0,V c 308.75' --. t 'R 4 umi �'
g ry j 2. Any Re-subdivision of this plot shall comply with the applicable Zoning
y �IJ I ¢ 2 Regulations in effect at the time of the Re-subdivision.
(I 58.00' 3 S 89'01'17'E
w I L9 LID I; Z 281.00' I 3. All lot lines common to public right-of-way within Medimont Subdivision No.1
as shown hereon shall hove a 10 wide Permanent Utilities, Drainage and Irrigation
a al I o s: BLOCK 1 n o¢ BLOCK 2 I Easement, unless otherwise dimensioned. However, this shall not preclude the con-
NI I� 4 5 S Iv°4 of struction of the
5
proper hard surfaced driveways for Access of each individual lot.
vi �I I +m 50 0 100 2w 4. The Developer and/or Owner sholl comply with Idaho Code, Section 31-3805
yg I SCALE: 1"=100' or its provisions that may apply to irrigation rights.
WO'WADE IRRIGATION PIPE 10' Si S B9'OtY 7"E o
EASEMENT FOR THE BENEFIT I o 5. The owner of each lot, across which passes an irrigation/drOinOgB ditch or
OF THE ME DIM ERS SUBDIw510N 1 281.00' 0 pipe, is responsible for the maintenance thereof unless such responsibility
I BUSINESS OWNERS ASSOCIATION N 89'01'17"W has been assumed by an Irrigation/Drainage District.
c 249.75' Z nl
_Ti 6. Reference is hereby made to Record of Survey No. 3471 filed as Instrument
J V 6 QP. '-I No. 96021918 for further survey information.
- w
N 89'01'17"W-T242.32' w 8 g s 7. The bottom elevation of building footings shall be a minimum of 12 inches
s no 6 2g•12g; '. N above the highest established seasonal groundwater elevation.
a 0 do _
^ a n� otl` y1 N 89'01'17" W 298,83' 8. Lot 1, Block 1; Lot 1 and Lot 2 Block 2 shall be owned and
maintained by the Medimont Subdivision Business Owners Association.
SW g m o ►gyp.ry1�
pP� N 190817" W N c^ 9. A permanent public utilities and irrigation easement is hereby designated over
NE I/" E N 89'01'17" W 249.75't/4 N Z 30.48' WITNESS CORNER I all of Lot 1, Block 1, and Lots 1 and 2, Black 2.
Section 18 5
10. Direct lot access to E. Franklin Road and to S. Adkins Way from the Franklin
UNPLATTED I Road Right-of-Way to a point 150' South is prohibited without approval from
I I the Ada County Highway District.
11. Driveway approach size and location shall be approved by The Ada County
Highway District.
�I 12. A Storm Water Drainage Easement is hereby reserved over Lot 1, Block 1 and
r Lot 1, Block 2 for the benefit of the Ada County Highway District. Landscaping
nl IH over said lots shall be maintained by the Medimont Subdivision Business Owners'
'a Association, and the Ado County Highway District shall provide heavy maintainence
�i,I of the storm drainage facilities as defined in the covenants,conditions and
N restrictions for Medimont Subdivision No. 1.
LINE TABLE 13. All lots within this subdivision are subject to the terms and conditions of a
LINE DIRECTION DISTANCE 31 INEE Development Agreement recorded as Instrument No. 97072405 in the records
Lt µ•7• 42.87 3 of Ada County, Idoho.
'5843 W 39.45 0l IM OWNER DEVELOPER:
L3 N "W 28.28 I v /
L4 N 4558'17" E 14.97 SN ut 2 6 n
N 44rorn•w us7 o N � Properties West, Inc.
N 35.41 0 to m� l1y.$ q�
N earot'17 w 29.D0 z CA �1K7! erz'te5 110reg'C c/o Jon L Barnes
1401 Shoreline Drive
1'1 E 29.00 I C'+RY A.�fE 9"t97�95""� Boise,
r1r 29.00 I I ID 2
L7 .1 17 1 3.41
(208)3 5-7523
Ltt N 0038'43'E 35.47
L12 N 4 '4"E 28.28 FOUND 1/2'IRON PIN,NO CAP ,J-U-B ENGINEERS, INC.
L13S 4445'1 E 28.28 AND CAP,
WITH 5/8"IRON PIN
L14 N '45'OS" 40.34 AND CAP,PE/LS 3260
LID S DD'58'43'W 1 33.1E Englrreers Surw}ors Planners
N 4522'30 E 41.98
S 89'2390.40 Boise, Idaho
'40" W '"on/DWI,
PLAT BOOK 5 PAGE y SHEET 1'OF 2
5
MEDIMONT SUBDIVISION No. I
CERTIFICATE OF OWNERS CERTIFICATE OF SURVEYOR
KNOW ALL MEN BY THESE PRESENTS: That Properties West Inc., an Idaho Corporation, licensed to do business in Idaho, I,Gory A.Lee,do hereby certify that I am a Professional Engineer and Professional Land Surveyor,licensed by the State of Idaho,and that this Plat of
does hereby certify that 't is the owner of o certain tract of land as shown on this plat and described as follows Medimont Subdivision No.1,as described in the Certificate of Owners and on the attached plat,was drown from an actual survey,made on the ground
and intend to include said land in this plat' under my direct supervision and accurately represents the points platted thereon,and is in conformity with the State of Idaho Code relating
A parcel of land situated in the NE 1/4,Section 18,Township 3 North,Range 1 to plots and surveys and the comer perpetuation and filing act,Idaho Code 55-1601 through 55-1612.
East,Boise Meridian,more particularly described as follows:
Commencing at a brass cap monumenting the HE comer of said Section 18; thence South 89*46,18"West NBSNEE,p/
480.70 feet along the Northerly boundary of said Section 18,also said boundary being the centerline of
East Franklin Road to a point; thence leaving said boundary and centerline South 02'14'38"East 45.03
feet to an Iron pin and 2"pipe manumenting the REAL POINT OF BEGINNING; thence continuing South
02'14'38"East 142.37 feet to an iron pin; thence South 00'58'43"West 494.50 feet to an iron pin; Gory A.Lee,P.EA S c 26 m License No.3260
thence South 19'08'17"East 135.59 feet to an iron pin; thence South 01'25'43"West 520.56 feet to an 57
I—pin on the Southerly boundary of the NE 1/4 NE 1/4 of sold Section 18; thence South 89'39'40"West
20.25 feet along sold boundary to an Iran pin; thence leaving said boundary North 0026'00"West 567.65 �rF gF Wei
feet to an iron pin; thence North 19*08'17"West 30.48 feet to an iron pin; thence North 89,01,17' O'fRY A.
West 298.83 feet to an Iron pin; thence South 44'32'46"West 84.15 feet to an on pin; thence North
89'01'17"West 249.75 feet to an Iron pin; thence North 00'58'43"East 106.00 feet to an Iron pin;
thence North 89'01'17"West 242.32 feet to an Iron pin on the Westerly boundary of said NE 1/4 Ni 1/4;
thence North 0029'39"East 645.00 feet along said boundary to on iron pin on the Southerly right of way
of said East Franklin Road.said pin bearing South 0029'39"Wast 25.00 feet from the NW comer of said •,,...r
HE 1/4 NE 1/4; thence leaving the Westerly boundary of said NE 1/4 NE 1/4 North 89'46'18"East 847.60 ADA COUNTY HIGHWAY DISTRICT COMMISSIONER'S ACCEPTANCE `'� CO••
feet along the sold right of way to an iron pin; thence South 02'14'38"East 20.01 feet to the REAL ,o°QP•, UIV•••i
POINT OF BEGINNING,containing 14.24 acres,more or leas. as 1Y
Th foregoing plot w accepted and approved by the Board of Ada County Highway District Commissioners on the��dayyf �••.
The public streets,as shown on this plat of Medimont Subdivision No.1,are hereby dedicated to the use of the public,and the easements indicated on 19
saitl plat are not dedicated to the public,but the right to use said easements is hereby reserved for public utilities and for any other uses as designated ADA COUNTY HIGHWAY DI``TRICT S I
hereon and no permanent structures are to be erected within the lines of said easements. f fill
All lots Shown M this plot of Medimont Subdivision 1 ore eligible to al domestic water service from the City of Meridian,Idaho,Municipal Water
System. Further,the City of Meridian,Idaho,has agreed
serve in writing to see all lots within Medimont Subdivision No.1 with domestic water. -airman ----�-------`- q Q
IN WITNESS WHEREOF,We have hereunto set our hands this BL- day of 11v.'arf /997. •••1.4 yr ..I...
P ernes W t, Inc. CERTIFICATE OF COUNTY SURVEYOR
I, J014M E. Professional Land Surveyor for Ada County,Idaho,hereby certify that I have checked this
Jon Barnes - President � �� plat of Medimont Subdivision o.1 and find that it complies with the State of Idaho Code relating to plats and surveys.
Larry B. Barnes - Secretary N
J and A Enterprises, An Idaho General Partnership
Jo6fes L. Boyd, General 43artner Amiletto J. Boyal Genera0artner OF Ar;
IA12.PR1�
CERTIFICATE OF ACKNOWLEDGMENT
STATE OF IDAHO
County of Ado) " APPROVAL OF CITY COUNCIL
4 I,the undersigned,City Clark Jp al far City of Meridian,Ada County,Idaho,do hereby certify that at a regular meeting of the City Council
On this 8 day of 1997,before me,the undereigned,a notary public in and for said stole, held on the day of+/ 199�this plat of Medimont Subdivision No.1 woe duly accepted and approved.
personally appeared Jon L 9 d lorry B.Barnes,known to me to be the President and Secretary of Properties
West Inc.,The corporation that executed the foregoing instrument and acknowledged to me that they executed the "p"` ,!•
same. ``��y ysFl,,,, r CO...
F"
IN WITNESS WHEREOF,I have hereunto set my hand and seal the day and year in this certificate first above written. v �yOTAq �'' "•````d� un �1
_� �• . * pU �G *= City Clerk,Meridian,Idaho
Note u is for Idaho B = sm e
Reading at �!Y Waa�i..
My Commission ,Expires: -z�ulvs '�`!}tTf Of W?��•' =7''=@ ��
rtst, ypcc
CERTIFICATE OF ACKNOWLEDGMENT ,of
STATE OF IDAHO ) APPROVAL OF CITY ENGINEER ��Oj""'""•�,
99
County of Ada) I,Gary Dean Smith,City Engineer in and for City of Meridian,Ada County,Idaho,hereby approve this plat of Medimont Subdivision No.1.
On this—�E day of before me,the undersigned,a notary pubic in and for the said state,personally appeared
James L.Boyd and Amiatto J.Boyd,kown or identified to me to be the partners in the partnership of J and A Enterprises,an Idaho
General Partnership and the partners,who subscribed said partnership's name to the foregoing instrument,and acknowledge to me that Egg r �JJ'
they executed the some. `W a, 61Np4
IN WITNESS WHEREOF,1 have hereunto set my hand and seal the day and year In this certificate first above written.
d1.9J OTAgA'- Gary Dean Smith,City EngineerOf
Notary ub is r Idaho * pV 8``G *, �4�DEAN AN
Residingat fi
My Commission Expires: O
CERTIFICATE OF COUNTY TREASURER ATf OF 0,
I,Barbaro Bauer,County Treasurer in and for the County of Ado,State of Idaho,par the requirements of I.C.50-1308,do her (I
COUNTY RECORDER'S CERTIFICATE
Thisthat any and.11 current and/or dli.qu.nt property taxes for the property included in this proposed subdivision have been p;iys only.
certification Is valid for the next thirty(30)
°w INSTRUMENT NO.-qXO.71013__
B.'rbCaunty Tre u _ STATE OF IDAHO)
BY
SS
Dot $U
e_J.� -��- - F,.I County of Ada) y
r"•^ 1 her b tify that this instrument wps fie at the request of )u1J F �/�A.n of QQ minutes past <la k
APPROVAL OF CENTRAL DISTRICT HEALTH DEPARTMENT s'Q.GS HBA'L"T'rI. this day of�ec_ �19��in my office and was duly recor °in Baok _of Plata at pages� and_I] m'
Sanitary reatrictians of this plot are hereby removed according to the letter to be read on file with the County Re{oxp or his��o�lg d•`•• '
listing the conditions of approval. yJ `
2 q€ ADA
a g COUNTY •O A= Deputy -Officlo Recorder
17
Centro'District Health Depa aWy� k��•�*"^"♦ FEE f11.00
Da1e___��19Z___'_"' SHEET 2 OF 2
Warranty Deed
Ada County Recorder Trent Tripple 2025-086015
Boise,Idaho Pgs=2 asteele 12/24/2025 11:17:05 AM
ALLIANCE TITLE-BOISE PRODUCTION CENTER$15.00
Electronically Recorded
At&
ALLIANCE
TITLE & ESCROW
WARRANTY DEED
Order No.: 1040313
FOR VALUE RECEIVED
TRK Properties LLC, an Idaho limited liability company
the grantor(s), do(es) hereby grant, bargain, sell and convey unto
Long Dog, LLC, an Idaho limited liability company
whose current address is:
2586 E Autumn Way
Meridian, ID 83642
the grantee(s), the following described premises, in Ada County, Idaho,
TO WIT:
Lot 4 in Block 2 of Medimont Subdivision No. 1 according to the official plat
thereof,filed in Book 75 of Plats at Page(s) 7794 and 7795, records of Ada County,
Idaho
TO HAVE AND TO HOLD the said premises, with their appurtenances unto the said
Grantee, heirs and assigns forever. And the said Grantor does hereby covenant to and with the
said Grantee(s), that (s)he is/are the owner(s) in fee simple of said premises; that they are free
from all encumbrances Except: Current Year Taxes, conditions, covenants, restrictions,
reservations, easements, rights and rights of way, apparent or of record. And that(s)he will
warrant and defend the same from all lawful claims whatsoever.
Dated: December 19, 2025
TRK Properties LLC
T . Ketlinski, Member
Instrument # 2025-086015
12/24/2025 11:17:05 AM Page 2 of 2
State of Idaho} ss
County of Ada}
On this 22nd day of December, 2025, before me, the undersigned, a Notary Public in and for
said state, personally appeared Todd R. Ketlinski known or identified to me to be the Member in
the Limited Liability Company known as TRK Properties, LLC who executed the foregoing
instrument in said LLC name and acknowledged that he/she/they executed the instrument in
said LLC name.
IN WITNESS WHEREOF, I have hp,-reurito set-my hand and affixed my official seal the day and
year in this.c otalirst above4ritten._.
No ry ublic forth tot6 of Idaho REANA GARC;IA
Residing at: COMMISSIO1\d#30929
Commis NOTARY PUBLIC:
�n Meridian, Idaho STATE OF IDAI••IO
My Commission expires: 11-5-202
REANA GARGIA
COMMISSION#30929
NOTARY PUBLIC
STATE OF IDAFIO