It is titled as an “amended verified complaint for declaratory judgment, and Preliminary and permanent injunctive relief.”

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https://www.gradickcommunications.com/wp-content/uploads/2022/03/amended-complaint-1.pdf

Solid Solutions is seeking declaratory judgment and injunctive relief against the Defendants in their official and individual capacities, in accordance with the Georgia Zoning Procedures Law, O.C.G.A. § 36-66-1 et seq, the due process clause of the Georgia Constitution, Article 1, Section 1, Paragraph 1, and other principles of Georgia statutory and constitutional law.

Solid Solutions seeks a declarative judgment against the Defendants declaring the Haralson County Zoning Ordinance to be invalid and unenforceable to or against Plaintiff and Plaintiff’s vested property rights under Georgia law to use the real property.

Solid Solutions requests the Court to issue a permanent injunction restraining and enjoining the Defendants from applying the legally invalid/ void Haralson County Zoning Ordinance to or against Plaintiff or Plaintiff°s vested property rights to use that real property for authorized lawful and beneficial uses under Georgia law.

Attorneys for Solid Solutions state: we respectfully submit on behalf of the Applicant that restricting the subject land to the current Agriculture/forestry zoning classification by denial of this request to rezone the subject property would be an unconstitutional decision and action by this Board of Commissioners. A decision by this Commission to deny the requested rezoning would be lacking a reasonable and rational basis, arbitrary, unconstitutional, and constitute a taking of this land for which Applicant has binding property rights in violation of the above-referenced constitutional requirements and Georgia decisional law; Denial of the requested rezoning would prevent an economically viable and more beneficial use of the land for this development project which is unquestionably its highest and best use. Moreover, a denial of the requested rezoning would not substantially advance relevant interests of the County or its citizens including those in the vicinity of the subject land.