IN THE CIRCUIT COURT OF WILSON COUNTY, TENNESSEE ‘TOM BRASHEAR, DIRECTOR OF WILSON COUNTY DEVELOPMENT SERVICES, Prin exer 23-WV- ['1| GLOBAL VISION BIBLE, INC. A.K.A GLOBAL VISION BAPTIST, INC. and GLOBAL VISION CHURCH and GREG LOCKE, individually, Defendants : COMPLAINT Comes the Pl iff and for cause of action says into the Court as follows: 1. The Plaintiff, Tom Brashear, brings this action in his official capacity as Director of Development Services for Wilson County, Tennessee. 2. The Defendant Global Vision Bible, Inc., upon information and belief, is an active non-profit corporation in the State of Tennessee. Itis also known as Global ion Baptist Church and Global Vision Baptist, Inc. Defendant Greg Locke is the Pastor of the Church, 3, The Defendants own real property in Wilson County, Tennessee in the name of Global Vision Baptist, Inc., a Tennessee Non-Profit Corporation, obtained in at least five warranty deeds of record in the Register’s Office of Wilson County, Tennessee in Book 2133, Pages 1240-1242; Book 2121, Pages 1411-1415; Book 2111, Pages 935-937; Book 1692, Pages 875-877; and Book 1678, Pages 100-102.The parcels, according to those deeds and the records of the Assessor of Property of Wilson County, Tennessee are at Map 73, Parcel 75, Parcel 76, Parcel 77, Parcel 78,01 and Parcel 78.02. The address of this property, according to the Records of Wilson County, Tennessee, is 2060 Old Lebanon Dirt Road, Mt. Juliet, Wilson County, Tennessee 37122. The property is zoned R-1. 4, This property, and the use thereof, has a history of numerous complaints, some of which are related to zoning violations and others about excessive noise. 5. The initial Complaint in this matter concerned the Church making an addition to the property without obtaining the proper permit for building and for obtaining the proper stormwater permit. The site plan previously presented for additions to an existing building had expired. 6. On July 11, 2019, an inspection was made of the property and it was discovered that an addition was in fact being constructed without a building permit and that ‘the stormwater permit previously granted has expired and must be renewed. A STOP WORK Order was issued at this location. Notice of Stop Work was given by the Plaintiff to Defendant Global Vision Baptist, Inc. on July 12, 2019 advising that the property was in violation of the Wilson County Zoning Or: constru tiff advised that the issue yn was occurring without a permit. The PI must be corrected to comply with the Zoning Ordinance. A copy of this Notice of STOP WORK is attached as “Exhibit A”.7. On August 12, 2019, a follow-up inspection was made and it was noted that the roof had been completed for purpose of protection from the weather and that work was currently stopped. 8. On September 4, 2019, a “Second Notice of Stop Work/Violation” was sent by the Plaintiff to Defendant Global Vision Baptist, Inc. The purpose of this letter was to remind the Defendant that the Construction on this property must be permitted within thirty (30) days, by October 4, 2019. A copy of this document is attached as “Exhibit B”. 9. On October 3, 2019, a follow-up inspection was made and determined that there was no further progress on the construction and a site plan would be required for addition to the structure. 10. On October 8, 2019, a “Final Notice of Stop Work/ Violation” was issued by the Plaintiff to Defendant, Global Vision Baptist, Inc., advising that the property is still in violation of the Wilson County Zoning Ordinance and the construction must be permitted within thirty (30) days, by November 7, 2019. 11. Follow-up inspections were made on November 7, 2019, December 13, 2019, and February 4, 2020. All determined there had been no change since the previous inspection and that no further work had taken place, but that the required permits had not been obtained. 12. Subsequently, Wilson County Stormwater determined that there was unpermitted earthwork taking place at Global Vision Baptist Church. Wilson County Stormwater placed a Stop Work Order on the property.13. On August 5, 2021, it was discovered from information provided to the Plaintiff that the Defendants had returned to bui ig without site plan approval or a permit. 14. On August 30, 2021, it was discovered that a new building had been delivered to Global Vision Church without receiving the appropriate building permit, site approval, and in violation of a Stop Work Order. 15. On October 27, 2021, applicant Greg Borchers made application, on behalf of the Church, to the Board of Zoning Appeals of Wilson County, Tennessee seeking to use the additional property for church use beyond the parcel that housed an existing Church building. At the hearing on November 18, 2021, the relief was granted, subject to conditions, those conditions being that all legal issues, stormwater issues and zoning issues must be resolved. To date, these issues remain unresolved and outstanding. 16. During the hearing of the Wilson County Zoning Appeals on November 18, 2021, testimony was presented regarding concerns about drainage, the construction ‘on the property and noise complaints. These complaints continue to this day. The complaints have increased in number and frequency from neighbors who suffer from the excessive noise, drainage from the property and other issues. 17. The Defendants, and this property, continue to be in violation of the State of, Tennessee and Wilson County Stormwater Department regulations and a Stop Work Order remains in effect. A photograph of that Stop Work Order is attached as “Exhibit C”.18. A “Notice of Stop Work” dated January 18, 2022 was mailed to Global Vision Baptist, Inc. by the Plaintiff. The notice states as follows: “The violation found on this property pertains to structure without permit. Site plan approval is also required for site use, parking, and stormwater management. Use approval was granted for additional parcels that the church has acquired in November 2021 by the Wilson County Board of Zoning Appeals. This approval was granted on the basis that all required Permits would be applied for. Site plans submittal and approval is required to receive such permits, inclusive of the necessary stormwater permits and necessary building permits for recent buildings that have been added to the Church property.” The notice goes on to describe how the property violates Section 6.20.25, 6.20.01 and 6.20.02 of the Wilson County Zoning Ordinance. 19. As of January 18, 2022, the property now is under a Stop Work Order from the Wilson County Zoning Administrator for zoning violations and a Stop Work Order from the Wilson County Stormwater Department for Stormwater Violations. 20. The “Notice of Stop Work” was returned to the office of the Wilson County Building Inspector and the “Notice of Stop Work” resent on February 3, 2022. 21. During this time, and continuing to date, citizen complaints on this property have increased in number and frequency. 22. Site plans should be inclusive of showing all buildings or structures that have been added and/or will be added in the near future. Site plans should also show means of dealing with drainage from the improvements to date as well as any proposed improvements in the near future. 23. Site plan submittal would be followed by review and ultimately result in stormwater and building permits being requested.24, During the last few weeks, the Defendants have erected on site a much larger tent which, according to a representative of the Church, is designed to decrease the sound coming from the Church services. With further complaints being received, an inspection has been made of the property and it appears that a ‘more permanent structure is going up around the tent in violation of the Stop Work Orders on this property. 25. The Plaintiff, and many other Wilson County Officials, have received numerous complaints about the activities taking place on this property. The Defendants have failed or refused to honor the lawful directions of the Plaintiff, Tom Brashear and his employees, including Wilson County Stormwater Director James Vaden and have refused to adhere to, and in fact appear to have ignored, the provisions of the Wilson County Zoning Ordinance and the conditional approval granted by the Wilson County Board of Zoning Appeals. 26. Upon information and belief from the facts discovered, these Defendants continue to operate without the appropriate approvals and have no intention of compliance. 27. The Defendants have placed a building, or buildings, without obtaining the proper building permits and approvals in violation of Wilson County Zoning Ordinance 6.20.01. 28, The Defendants, and each of them, have refused to acknowledge and comply with the requirements of the Wilson County Zoning Ordinance, and conditional approval of the Wilson County Board of Zoning Appeals, contained in the Lettersof Violation sent by the Plaintiff and continue to operate and function in violation of the Wilson County Zoning Ordinance at the time of the g of this ‘Complaint. 29, Plaintiff avers that the Defendants have violated the Zoning Ordinance of Wilson County, Tennessee, continue to violate the same, and have indicated their disregard of all lawful directives received from the Plaintiff in furtherance of ‘compliance with the Wilson County Zoning Ordinance. Therefore, these Defendants should be permanently enjoined from the continued violation of the Zoning Ordinance until such property is brought into compliance with the Wilson County Zoning Ordinance. 30. Plaintiff avers that the Defendants have violated the Stormwater regulations of Wilson County, Tennessee, continue to violate the same, and have indicated their disregard of all lawful directives received from the Plaintiff in furtherance of compliance with the Wilson County Stormwater regulations. Therefore, these Defendants should be permanently enjoined from continued violation of the Wilson County Stormwater Regulations until they bring their property into full compliance with those regulations. PREMISES CONSIDERED, Plaintiff prays: 1. That service of process issue and be served on each Defendant requiring them to answer this Complaint within the time allowed by Law. 2. That the Defendants, and each of them, be prohibited from the continued violation of the Wilson County Zoning Ordinance, and the Wilson County‘Stormwater Regulations and required to bring their property into compliance all aspects with the Wilson County Zoning Ordinance, Wilson County ‘Stormwater Regulations and the conditional approval granted by the Wilson County Board of Zoning Appeals. 3. That the Defendants, and each of them, be found to be in violation of the Zoning Ordinance of Wilson County, Tennessee and the Wilson County ‘Stormwater Regulations and, should they fail to bring their property into complete compliance, be required to remove all buildings from the property and be permanently enjoined from placing any other buildings on the property until there is full and strict compliance with the Wilson County Zonit 1g Ordinance and the Wilson County Stormwater Regulations. 4, That the Pla iff have all the general relief to which he may be found entitled. ‘Tom Brashear, Director of Wilson County Development Services Michael R. Jeni Wilson Count? Attorney 326 North Cub(berland Street Lebanon, Tennessee 37087 (615) 444-0585 telephone (615) 449-8239 facsimileOATH ‘STATE OF TENNESSEE ‘COUNTY OF WILSON |, TOM BRASHEAR, Director of the Wilson County Development Services/Building inspection Division and Piaintiff in the above styled cause, hereby make oath that the statements in the foregoing Complaint are true to the best of my knowledge, information and belief. 4 4 D5. Z—- Atma ———— , Director Wilson County Building Inspector, Zoning ‘Administrator and Development Services Director + sworn to and subscribed before a Notary this the _21°* day ot_ March 2023 NOTARY PUBI el MY COMMISSION EXPIRE! Noe 04 og /2022 NG )E SURETY Jeg Wilson County, Tennessee is the surety for the cost of this cause. REExniet A "WILSON COUNTY BUILDING INSPECTOR 233 EAST GAY STREET, WILSON COUNTY COURTHOUSE ANNEX LEBANON, TN 37087 PHONE (615) 444-3025, FAX (615) 443-6194 NOTICE OF STOP WORK July 12, 2019 Global Vision Baptist Inc 2060 Old Lebanon Dirt Rd ; Mt Juliet TN 37122 7 RE: 2060 Old Lebanon Dirt Rd., Tax Map 73 Parcel 77, zoned R-I, consisting of acre —- To Whom It May Concern, Upon a recent inspection of the county, our inspectors noticed that the above listed property is in violation of the Wilson County Zoning Ordinance. The violation found on this property pertains to building without a permit. The construction on this property must be permitted within in thirty (30) days, by August 12, 2019. To comply with the Wilson County Zoning Ordinance and prevent further action from being taken by this office, the above listed issues must be corrected to comply with our zoning ordinance. Please contact our offices to let us know how you wish to address the issues that have been outlined in this notification letter. If these options listed above cause any conflict, you may have the option of going before BOZA regarding this matter. Sincerely, Bey Lithia Tom Brashear Wilson County Director of Development Services TB/mm Ceffile- District 2, Commissioner Cyndi BannachExit & WILSON COUNTY BUILDING INSPECTOR 233 EAST GAY STREET, WILSON COUNTY COURTHOUSE ANNEX LEBANON, TN 37087 PHONE (615) 444-3025 FAX (615) 443-6194. 28” NOTICE OF STOP WORK/ VIOLATION September 4, 2019 Global Vision Baptist Inc a] 2060 Old Lebanon Dirt Rd Mit Juliet TN 37122 < RE: 2060 Old Lebanon Dirt Rd, Tax Map 73 Parcel 77, zoned R-I, consisting of l-acre To Whom It May Concern, Upon a recent inspection of the county, our inspectors noticed that the above listed property is in violation of the Wilson County Zoning Ordinance. The violation found on this property pertains to building without a permit The construction on this property must be permitted within in thirty (30) days, by October 4, 2019. To comply with the Wilson County Zoning Ordinance and prevent further action from being taken by this office, the above listed issues must be corrected to comply with our zoning ordinance. Please contact our offices to let us know how you wish to address the issues that have been outlined in this notification letter. If these options listed above cause any conflict, you may have the option of going before BOZA regarding this matter, Sincerely, of Liat ‘Tom Brashear Wilson County Director of Development Services TB/mm Ceffile- District 2, Commissioner Cyndi BannachExnilot C. WILSON COUNTY BUILDING INSPECTOR 233 EAST GAY STREET, WILSON COUNTY COURTHOUSE ANNEX LEBANON, TN 37087 PHONE (615) 444-3025 FAX (615) 443-6194 NOTICE OF STOP WORK February 3, 2022 GLOBAL VISION BAPTIST INC. 2060 OLD LEBANON DIRT RD MOUNT JULIET, TN 37122 RE: 2060 Old Lebanon Dirt Rd., Tax Map 73 Parcel 78.01, zoned R-1, consisting of 6.70 acres To Whom It May Concern: Upon a recent inspection of the county, our inspectors noticed that the above listed property is in violation of the Wilson County Zoning Ordinance. The violation found on this property pertains to structure without permit. Site plan approval is also required for site use, parking, and storm water management. Use approval was granted in November, 2001 by Wilson County Board of Zoning Appeals on the basis that all required permits would be applied for. Site plan submittal and approval is required. ‘SECTION 6.20.25 SITE PLAN REQUIREMENTS (resolution 02-3-6) In no event shall a new commercial, industrial, multi-family residential, public assembly or institutional structures or additions, including new construction/new establishment of parking lots or outdoor storage yards or outdoor display areas be erected on a property without prior review and approval of a site plan by the Wilson County Planning Commission (Or Board of Zoning Appeals in the case of Multi-Family Residential Use). Said site plan shall be prepared by an individual licensed and/or certified by the State of Tennessee to perform such design service as may be required, where applicable, The above listed amendments shall take effect upon approval of this amendment; the general welfare of the public requiring it. No part of this regulation shall have any impact on pre-existing use or use on appeal approvals. The Regulations in place at the time of approval of such activities shall take precedent. (resolution 18-11-13) Finally, the site plan shall include the following items: 1. The actual shape, dimensions, size, and location of the lot. HAYWILSON COUNTY BUILDING INSPECTOR 233 EAST GAY STREET, WILSON COUNTY COURTHOUSE ANNEX LEBANON, TN 37087 PHONE (615) 444-3025 FAX (615) 443-6194 b. The shape, size, and location of all buildings or other structures to be erected, altered, or moved and of building or other structures already on the lot. c. The existing and intended use of the lot. d. Existing topographic features including contours at 2-foot intervals, where applicable. SECTION 6.20 BUILDING PERMITS, SITE PLAN REQUIREMENTS: AND CERTIFICATES OF COMPLIANCE 6.20.01 BUILDING PERMIT REQUIRED. It shall be unlawful to In the commence excavation for the construction of any structure including accessory structures, or to commence the moving or alteration of any structure including accessory structures, until the Building Inspector has issued a building permit for such work. The building permit fee schedule shall be set by the Wilson County Commission. event that construction or excavation work has begun by an individual, partnership, or corporation prior to obtaining a building permit, and a permit is then applied for, either voluntarily or at the request of the Building Inspector, a letter of warning shall be issued for the first incidence of non- compliance by the person, partnership, or corporation. For any subsequent incidence of non-compliance, the building permit fee shall be doubled. (resolution 18-11-13) ALPSWILSON COUNTY BUILDING INSPECTOR 233 EAST GAY STREET, WILSON COUNTY COURTHOUSE ANNEX LEBANON, TN 37087 PHONE (615) 444-3025, FAX (615) 443-6194 276 6.20.02 In applying to the Building Inspector for a building permit, the applicant shall submit a dimensional sketch or a scale plan indicating the shape, size and location of all structures to be erected, altered, or moved, and of any structures already on the lot. The applicant shall also state the existing and proposed use of all such structures and supply such other information as may be required by the Building Inspector for determining whether the provisions of this regulation are being observed. If the proposed excavation or construction as set forth in the application is in conformity with the provisions of this regulation and any required State of Tennessee Department of Environment and Conservation approval has been obtained, and any required permits or direction from the Flood Plain Administrator and the Storm Water Department have been obtained (resolution 18-11-13); then the Building Inspector shall, within three (3) days, issue a building permit for such excavation and/or construction. If a building permit is refused, the Building Inspector shall state such refusal in writing with the cause. [resolution 07-7-4] The issuance of a building permit shall in no case be construed as waiving any provision of this regulation. A building permit shall become void twelve (12) months from the date of issuance by the Building Inspector or the date an appeal is granted by the Board of Zoning Appeals, unless substantial progress has been made within those twelve (12) months on the project described therein. Substantial progress shall be determined by the request for and approval of subsequent required inspections from and by the Building Inspector respectively. In no case shall an active building permit for a residential dwelling last longer than 24 months without having received a certificate of compliance or other final approval as outlined within the Wilson County Zoning Resolution. If a permit recipient for a residential dwelling perceives that his construction project may last longer than 24 months, then special relief or variance from this provision will be required and the permit recipient will need to seek such relief from the Wilson County Board of Zoning Appeals. (resolution 18-11-13) AIPWILSON COUNTY BUILDING INSPECTOR 233 EAST GAY STREET, WILSON COUNTY COURTHOUSE ANNEX LEBANON, TN 37087 PHONE (615) 444-3025 FAX (615) 443-6194 ‘The construction on this property must be permitted within in thirty (30) days, by March 3, 2022. To comply with the Wilson County Zoning Ordinance and prevent further action from being taken by this office, the above listed issues must be corrected to comply with our zoning, ordinance. Please contact our offices to let us know how you wish to address the issues that have been outlined in this notification letter. If these options listed above cause any conflict, you may have the option of going before BOZA regarding this matter. Sincerely, “ f LZ te ‘Tom Brashear Wilson County Director of Development Services TB/mm Ceifile- District 2, Commissioner Rick Brown