La Grange Issues With 30 S. La Grange Road

LAGRANGE
Village of La Grange
53 S. La Grange Road, La Grange, IL 60525
lagrangeil.gov
RESPONSE TO REQUEST FOR PU BLI C RECO RDS
To: Patch .com

Attn : David Giuliani
david .giuliani@patch .com
On March 12, 2024, the Village of La Grange received your written request for
inspection, copying, or certification of the following Village public records :
See attached rider.
1. Decision on Request
~ Your request is approved in part and denied in part. Those records for which
your request is denied are identified in Section 3 below.
2. Ava ilability of Re cords
Subject to payment of any required fees or postage pursuant to Section 4 or 5 below,

all of the public records for which your request is approved will be made available as
follows. (See Section 6 for the public records for which your request is denied.)
Copies of the following public records wil l be:
~ Sent to you via email at the email address you provided in your request.
3. Denial of Request
Your request is denied as to the following records or redacted information conta ined
in those records :
FOIA response has been redacted as provided by the Illinois Freedom of Information
Act.
A. Responsible Official. The Village's FO IA Officer is the official responsible for
this denial.
B. Notice of Right to Review by Illinois Attorney General. You have the right to file
a request for review of your request and th is Notice of Denial by the Public
Access Counselor of the Office of the Illinois Attorney General. The Public
Access Counselor may be contacted at 500 South 2nd Street, Springfield,
Illinois 62706, or by telephone at (217) 558-0486.
C. Notice of Right to Judicial Review. Under Section 11 of the Illinois Freedom of
Information Act, 5 ILCS 140/11 , you have the right to seek judicial review of this
denial. The Village cannot advise or represent you in this matter. You should
consult your own legal counsel.
D. Justification for Denial. Your request is being denied with respect to the
specified records because the specified records are exempt from disclosure
pursuant to the Illinois Freedom of Information Act for the following reason or
reasons (references are to sections of the Act):
_x_ The records are private information . § 2(c-5), §7(1)(6)
Applies to: _ _ _ _ _ _ _ _ _ _ _ __ _ '--'
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um~ e~n=ts
March 27, 2024

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~
Daisy Cabrera
From : David Giuliani <david.giuliani@patch .com>

Sent: Tuesday, March 12, 2024 8:53 AM
To : FOIAGroup
Subject: Public Records Request-Nicksons Eatery Building
Litigation
Follow Up Flag: Follow up

Flag Status: Completed
![EXTERNAL EMAIL) Verify sender and use caution when opening atta chments or clicking links
Hello,
This is a public records request under the Freedom of Information Act.
At Monday's Village Board meeting, officials noted that the village was in lit igation with t he owner of the building at 30 S.
la Grange Road, where Nicksons Eatery once was . I am seeking copies of the lawsuit and t he owner's response. I am also
seeking previous correspondence between the owner and the village regarding code issues .
If you have any questions about this request, please feel free to contact me .
Thanks,
David Giuliani
Reporter
Patch .com
505-426-5067
Covering Elmhurst, La Grange, Hinsdale, Darien, Western Springs, Burr Ridge, Clarendon Hills
lagrangeil.gov
October 17, 2023
Adam Clabaugh
Andrew Nast
30 La Grange LLC
11 N Northwest Hwy, Suite 101
Park Ridge, IL 60068-0000
William Lundgren
55 W. Monroe St, Suite 3330
Chicago, IL 60603-5094
RE: 30 S. La Grange Road – Formal Notice of Code Violations and Courtesy Notice of Expiration
of Prior Approvals and Pending Applications
Messrs Clabaugh, Nast, and Lundgren:
The purpose of this letter is to advise you of the expiration of several prior approvals and
pending applications for 30 S. La Grange Road and to notify you of the required timeframe to
correct current code violations on the property.
Expiration of Prior Approvals and Pending Applications

On July 12, 2021, the Village Board of Trustees approved Ordinance O-21-11, granting a zoning
code text amendment, special use permit, site plan approval, and design review permit to
authorize co-working in conjunction with retail sales at 30 S. La Grange Road.
On April 7, 2022, a permit authorizing interior demolition only was issued pursuant to an
application dated April 4, 2022. On June 7, 2022, an application for fire alarm permit was
submitted; on June 8, 2022 Andrew Nast was advised that an application for a building permit
and an application for a fire sprinkler system permit were also required. On July 1, 2022, an
application for a building permit was submitted. To-date, no application has been submitted for
a fire sprinkler system permit.
30 S. La Grange Rd. Notice
Page 2
On July 15, 2022, plan review comments on the building permit application were provided to
the applicant; the review comments noted that the proposed plans did not conform to the
requirements of O-21-11 and requested information to clarify other proposed plan elements.
On August 23, 2022 an application to amend the Design Review Permit for 30 S. La Grange
Road was submitted; this application was approved on October 10, 2022 by Ordinance O-22-
17. No further permit submittals have been received to-date. The Village’s last correspondence
with Brick & Mortar was an email exchange between Michael DeLillo and Andrew Nast on
February 7, 2023 regarding a potential future submittal of the required fire sprinkler system
permit application.
Per Section 14-401I of the La Grange Zoning Code, subject to an extension of time granted by
the Village Manager pursuant to Subsection 13-101L of this Code, no special use permit shall
be valid for a period longer than one year, unless a building permit is issued and construction is
actually begun within that period and is thereafter diligently pursued to completion or unless a
Certificate of Occupancy is issued and a use commenced within that period.
Per Section 14-402H of the La Grange Zoning Code, subject to an extension of time granted by
the Village Manager pursuant to Subsection 13-101L of this Code, no site plan approval shall be
valid for a period longer than one year unless a Building Permit is issued and construction is
Certificate of Zoning Compliance is issued and a use commenced within that period.
Per Section 14-403H of the La Grange Zoning Code, a Design Review Permit shall become null
and void six months after the date on which it was issued unless within such period the work
authorized by such certificate is commenced.
La Grange Building Code Section 150.09.B.5 establishes that any application for permit for any
proposed work shall be deemed to have been abandoned 180 days after the filing or date of
last action, unless the application has been pursued in good faith or a permit has been issued;
except the Building Official is authorized to grant an extension of time provided the request is
received in writing and justifiable cause is demonstrated.
As of the writing of this letter, it has been over two years since approval of the special use permit
and site plan for 30 S. La Grange Road granted in O-21-11, over one year since the approval of
the amended design review permit for 30 S. La Grange Road granted in O-22-17, and over six
months since the last correspondence related to pending building permit application(s) for 30
S. La Grange Road. Accordingly, this letter serves as a courtesy notice that all zoning approvals
granted by O-21-11 and O-22-17 are null and void and all pending building permit applications
are deemed abandoned.
Code Violations
After completing a survey October 17, 2023, it has been noted that the specified address above
currently violates the following codes (text in italics describes the current violations):
Page 3
• PM-301.3 Vacant structures and land. Vacant structures and premises thereof or vacant land
shall be maintained in a clean, safe, secure and sanitary condition as provided herein so as
not to cause a blighting problem or adversely affect the public health or safety. (Destroyed
menu box at the front of the building, broken tiles at front entrance, paper in windows)
• PM-302.3 Sidewalks and driveways. Sidewalks, walkways, stairs, driveways, parking spaces
and similar areas shall be kept in a proper state of repair, and maintained free from
hazardous conditions. (Deteriorated concrete at scupper rear going into the ground)
• PM-302.9 Defacement of property. No person shall willfully or wantonly damage, mutilate or

deface any exterior surface of any structure or building on any private or public property by
placing thereon any marking, carving or graffiti. It shall be the responsibility of the owner to
restore said surface to an approved state of maintenance and repair. (Graffiti at 2 rear
vestibules)
• PM-304.2 Protective treatment. Exterior surfaces, including but not limited to, doors, door
and window frames, cornices, porches, trim, balconies, decks and fences, shall be
maintained in good condition. Exterior wood surfaces, other than decay-resistant woods,
shall be protected from the elements and decay by painting or other protective covering or
treatment. Peeling, flaking and chipped paint shall be eliminated and surfaces repainted.
Siding and masonry joints, as well as those between the building envelope and the perimeter
of windows, doors and skylights, shall be maintained weather resistant and water tight. Metal
surfaces subject to rust or corrosion shall be coated to inhibit such rust and corrosion, and
surfaces with rust or corrosion shall be stabilized and coated to inhibit future rust and
corrosion. Oxidation stains shall be removed from exterior surfaces. Surfaces designed for
stabilization by oxidation are exempt from this requirement. (Tuck-pointing deteriorated out
the alley south west corner top of building, peeling paint south west corner bottom, peeling
paint windows at alley second-floor, tuck-pointing at front entrance deteriorated, peeling
paint with damaged substrate at front entrance, including window frames, de-laminated
concrete at alley wall. Please note, tuckpointing requires a permit.)
• PM-304.13 Window, skylight and door frames: Every window, skylight, door and frame shall
be kept in sound condition, good repair and weather tight. (Rusty rear door at west side)
• PM-304.5 Foundation walls: All foundation walls shall be maintained plumb and free from
open cracks and breaks and shall be kept in such condition so as to prevent the entry of
rodents and other pests. (Damaged foundation at dumpster.)
Please take this opportunity to correct the violations. A re-inspection of the property will be
made on or about November 17, 2023 in order to determine compliance. Should you not be
able to complete the aforementioned items in the requested timeframe, you must contact
Environmental Health Officer Curt Trusner to discuss an alternative timeframe. Should you have
any questions, please feel free to contact Mr. Trusner at 708-579-2320 X 105. Thank you for
your time and consideration on this matter.
Page 4
Sincerely,
VILLAGE OF LA GRANGE
Charity Jones, AICP

Deputy Village Manager / Community Development Director
708-579-2320
cjones@lagrangeil.gov
IN THE CIRCUIT COURT OF COOK COLINTY ILLINOIS
MUNICIPAI DEPARTMENT. FIFTH DI STRICT
VILLAGE OF LA GRANGE, an Illinois )

Municipal Corporation, )
)
Plaintiff. )
)
) No.
)
30 LA GRANGE LLC, PARK zuDGE COMMUNITY )
BANK, LINKNOWNOWNERS, UNKNOWN )
OCCUPANTS and NON RECORD CLAIMANTS. )
Defendants.
SUIT TO ENFORCE POLTCE POWER _ COMPLAINT FOR FINE, DEMOLITION,

INJUNCTIVE, AND OTHER RELIEF _ EXEMPT OF FILING FEES
NOW COMES the Plaintiff, VILLAGE OF LAGRANGE, a municipal corporation, by

and through its attorneys, FALOON & KENNEY, LTD.. and for its Complaint against
Defendants, represents to the Court as follows:
COUNT I _ INJUNCTIVE RELIEF
l. PlaintiffVillage of La Grange ("LA GRANGE") is a municipal corporation located in the
County of Cook, State of Illinois.
2. Defendant 30 LA GRANGE LLC("OWNER") is the record owner of the property
commonly known as 30 South La Grange Road (the "Property"), located in the Village of La
Grange, County of Cook. State of lllinois.
3. Defendant PARK RIDGE COMMUNITY BANK ("PARK RIDGE") is the holder of a
mortgage upon the Property.
4. That there are persons in addition to those herein named defendants whose names are
unknown, who do or may claim some right. title, interest in or lien in fee or some lesser estate,
vested or contingent, to, or upon the real estate herein above described, or some part or parts
thereof, and that the name or names or any such persons are unlnown to the Plaintiff; that upon
due and diligent inquiry their names cannot nor can any oftheir names be ascertained; and
therefore makes all such persons parties defendant to this Complaint by the name, style. and
description of "LTNKNOWN OWNERS', 'UNKNOWN OCCUPANTS" and "NONRECORD
CLAIMANTS''.
5. Plaintiffalleges that the right, title, and interest ofeach and every one ofthe persons or
entities made party defendant herein is subject. inierior. and subordinate to the right ofthe
Plaintiff for a lien for all legal costs, attomeys'fees and other expenses in maintaining these
proceedings and for the cost and expense ofany demolition or repair conducted pursuant to any
order or decree entered herein.
6. 65 ILCS 5/11-31-1 provides in part that if a structure contains an emergency or incurable
safety or health hazard then the Court has the authoritv to issue its order to demolish, repair or
board-up said structure.
8. 65 ILCS 5/11-31-2 further provides in part that ifa structure constitutes a safety or health
hazard then the Court has the authority to issue a permanent injunction to cure these conditions
under such terms and conditions as will do justice.
9. At all times pertinent hereto. Section 301.3. ofChapter 150.24 of Title 15 of the LA
GRANGE CODE provided as follou's:
PM-301.3 Vacant Structures and Land: All vacant structures and premises thereof or
vacant land shall be maintained in a clean. safe. secure and sanitary condition as provided herein
so as not to cause a blighting problem or adversely affect the public health or safety.
10. That on the dale set forth herein and on numerous other occasions. violations of Section
301.3, of Chapter 150.24 of Title 15 of the LA GRANGE CODE existed in said property due a
2
destroyed menu box in front of building, broken tiles at the front entrance, and papered over
windows.
11. At all times pertinent hereto, Section 302.3, of Chapter 150.24, of Title 15, of the LA
GRANGE Code of Ordinances provided as follows:
PM-302.3 Sidewalks and Driveways. All sidewalks, walkways, stairs, driveways,

parking spaces and similar areas shall be kept in a proper state of repair, and maintained
free from hazardous conditions.
12. That on the date set forth herein and on numerous other occasions, violations of Section
302.3, of Chapter 150.24 of Title l5 of the CODE existed in said property due to a deteriorated
concrete at the rear scupper.
13. At all times pertinent hereto. Section 302.9, of Chapter 150.24 of Title 15 of the LA
GRANGE CODE provided as follows:
PM-302.9 Defacement of Property. No person shall wilfully or wantonly damage,

mutilate or deface any exterior surface of any structure or building on any private or public
property by placing theron on any marking, carving or graffiti. It shall be the responsibility of
the owner to restore said surface to an approved state of maintenance and repair.
14. That on the date set forth herein and on numerous other occasions, violations of Section
302.9 of Chapter 150.24 of Title 15 of the LA GRANGE CODE existed in said property due to
graffiti at the two (2) rear vestibules.
15. At all times pertinent hereto, Section 304.2 of Chapter 150.24 of Title l5 of the LA
304.2 Protective treatment
Exterior surfaces. including but not limited to. doors, door and rvindorv frames. cornices,
porches" trim. balconies. decks and fences, shall be maintained in good condition.
Exterior wood surfaces. other than decav-resistant r,l'oods. shall be protected from the
elements and decay by painting or other protective covering or treatment. Peeling.
3
flaking and chipped paint shall be eliminated and suriaces repainted. Siding and
masonry joints. as u ell as those betqeen the building enr ekrpe and the perimeter of
uindou's. doors and skllights. shall be maintained r,reather resistant and $ater tigh1.
Metal surf'aces sub.lect to nlst or corrosion shall be stabilized and coated to inhibit future
rust and corrosion. Oxidation stains shall be rernor ed fiorn exterior surl'aces. Surlaces
designed fbr stabilization b1' oxidation are exempt liorn this requirernenl.
16. That on the date set forth herein and on numerous other occasions. violations of Section
304.2. of Chapter 150.24 of Title l5 of the LA GRANGE CODE existed in said property due to
tuckpointing deteriorated out the alley southwest comer top ofbuilding, peeling paint southwest
comer bottom, peeling paint windows at alley second floor. tuck-pointing at front entrance
deteriorated, peeling paint with damaged substrate at front entrance, including window frames,
and delaminated concrete at alley wall.
17 . At all times pertinent hereto, Section 304.1 3 of Chapter 1 50.24 of Title 15 of the LA
304.13 Window, skllight and door frames
Elery r.r'indou-. skl tight. door and iianie shall be kept in sound condition. good repair and
rveatlre[ tiglit
18. That on the date set forth herein and on numerous other occasions. violations ofSection
304.13, of Chapter 150.24 of Title l5 of the LA GRANGE CODE existed in said property due to
the rusty rear west side door.
19. At all times pertinent hereto, Section 304.5, of Chapter 150.24 ofTitle 15 of the LA
PM-304.5 Exterior Walls. All exterior walls shall be free from holes, breaks, loose or
rotting materials; and maintained weatherproof and properly surface coated where required to
prevent deterioration.
4
20. That on the date set forth herein and on numerous other occasions, violations ofSection
304.5, of Chapter 150.24 of Title l5 of the LA GRANGE CODE existed in said property due to
damaged foundation at the dumpster.
21. On October 17,2023, LA GRANGE Deputy Village Manager Charity Jones mailed to
representatives of the OWNER a written CODE violation notice as to the above violations. A
true and accurate copy ofthe Notice is attached hereto as Exhibit -A".
22. Despite a request that the OWNER bring property in compliance with LA GRANGE
Village Code, no repairs or improvements have been made to the Code violations cited above.
23. Accordingly, said building was. on the date set forth , and at all times thereafter. in
violationofSections5/11-31-15,5/ll-31-1 and 5/ll-31-2 ofChapter 65 ofthe Illinois Municipal
Code; and Sections 301.3, 302.3. 302.9.304.2,304.13. and 304.5 of the LA GRANGE CODE'
24. That the violations alleged herein exist currently.
25. That the lerying ofa fine is not an adequate remedy for the abatement ofthe nuisance
caused by this structure, and that it is necessary for a temporary and permanent injunction issue.
The Village of La Grange seeks this relief pursuant to the injunctive relief provided by Section
150.105 ofthe Code ofOrdinances of the Village ofLa Grange, by 65 ILCS 5/11-31-1 and 65
rLCS 5/t1-31-2.
26. That Charity Jones of LA GRANGE has determined said building to be dangerous,
unsafe, and unhealthy.
27 . LA GRANGE has no adequate remedy at law'. Its purpose by this Complaint is to
uphold and sustain its zoning ordinances and Municipal Code for the common good and welfare
of the residents of LA GRANGE. Pursuant to Section 106.3 of Chapter I 50.24 of Title 15 of the
LA GRANGE CODE, LA GRANGE seeks equitable injunctive relief to correct the above
mentioned violations.
WHEREFORE, Plaintiffprays. pursuant to LA GRANGE Code Sections 301.3, 302.3, 302.9,

304.2,304.13, and 304.5, pursuant to 65 ILCS 5i 11-31-15 and/or 65 ILCS 5/11-31-1 and/or 65
ILCS 5/11-31-2:
(A) For a temporary and permanent injunction requiring the Defendants to take such
measures as to insure the health and safetv conditions at the property commonly known as 30
South La Grange Road in La Grange;
(B) For a temporary and permanent injunction requiring the Defendants to take such
measures as to timely complete the remediation on the site:
(C) For the appointment of a receiver. if necessary, to correct the conditions alleged in
the Complaint with the full power ofreceivership, including the right to issue and sell Receiver's
Certificates;
(D) For recovery of statutory fees and costs per 65 ILCS 5/11-13-1 and 1l-31-2;
(E) For such other and further relief as ma1' be necessary in the premises and which the
Court shall deem necessary; and
(F) For municipal violation fines in an amount of $75.00 to $750.00 per day per
violation.
COTINT II _ VIOLATION OF LA GRANGE CODE _ FINES AND PENALTIES
l-27. Plairtiff LA GRANGE realleges and reavers Paragraphs One through Twenty Seven of
Count I as Paragraphs One through Twenty Seven of Count II.
28. The aforementioned violations of LA GRANGE CODE. constitute continuous, ongoing
and pervasive violations of its zoning and building regulations as set forth in Sections 301.3,
302.3,302.9.304.2.304.13. and 304.5 of the LA GRANGE CODE.
29. That Section 150.20 of Title 15 of the LA GRANGE CODE provides for a fine an
amount ofno less than $75.00 and no more than $750.00 per day per violation.
WHEREFORE, Plaintiff, the VILLAGE OF LA GRANGE, respectfully requests that this Court
enter a fine against Defendants 30 LA GRANGE LLC, PARK RIDGE COMMLINITY BANK,
b
UNKNOWN OWNERS, UNKNOWN OCCUPANTS and NON RECORD CLAIMANTS in the
amount of five hundred dollars ($500.00) per violation of Section 106.2 of CODE Chapter
150.24, Title 15, for each day each violation has existed and/or continued in violation of the LA
GRANGE CODE, and for such other and further relief as the Court deems just and necessary in
the circumstances.
a Municipal Corporation
lsl John M. Kenney
One of Its Attorneys
John M. Kenney
Faloon & Kenney, Ltd.
5 S.6th Avenue
La Grange, Illinois 60525
708.579.3400
Firm No. 37250
john@fklegal.com
7
VERIFICATION
Under penalties as provided by law pursuant to Section 735 ILCS 5/l -109 ofthe Illinois
Code of Civil Procedure, the undersigned certifies that the statements set forth in this instrument
are true and correct, except as to matters therein stated to be on information and beliefand as to
such matters the undersigned certifies as aforesaid that he verily believes the same to be true.
Charity Jones
Subscribed and Swom to before me

this/Lday ol vruta** -.2024
o---7-- DAISY CAERERA
Ofrcial Seal
Notary Public - State of lllinoj5
My Commisiion Expjre5Apr 14, 2026
8
Maureen Rush
From: Kelsey Fawell <kfawell@lagrangeil.gov>

Sent: Friday, December 22, 2023 2:28 PM
To: Andrew Nast
Cc: Charity Jones; Daisy Cabrera; Maureen Rush; Mike DeLillo; Adam Clabaugh
Subject: RE: 30 S. La Grange Rd, La Grange | Restaurant Concept
Attachments: 30 S La Grange Rd 1st Notice.pdf
Hi Andrew,
Thank you for providing additional information regarding the proposed use of 30 S. La Grange Road. The property’s
previously granted special use permit is expired. A detailed notice regarding code violations and expiration of prior
approvals/applications is attached for your convenience; dated and sent to you on October 17, 2023.
The list of permitted and special uses allowed within the C‐1CR District, which 30 S. La Grange Rd. is zoned, can be found
within Article 5 of the Zoning Code. Per Section 5‐102, a restaurant use is permitted by‐right within the C‐1CR District
(no special use permit required). Office uses, such as the coworking you proposed, are only allowed as a permitted use
when not located on the ground floor within the C‐1CR District. Per Section 5‐105 of the Village Zoning Code, coworking
space on the first floor in conjunction with retail sales, subject to additional conditions, is a special use within the C‐1CR
District.
I will also take this time to remind you of the outstanding property maintenance and code violations on the property
that need to be corrected and that any pending zoning application does not change the obligation to timely remedy the
outstanding violations. In addition to the remedies provided for elsewhere in Village Code, per Section 150.08(G) of the
Village Building Code, the village may withhold any permit, until outstanding violations has been resolved in their
entirety.
Don’t hesitate to contact me with any additional questions. Enjoy the upcoming Holidays,
Kelsey Fawell
Village Planner
53 S. La Grange Road
La Grange, IL 60525
PH: 708-579-2300 ext. 104
lagrangeil.gov
** Online permiting is now available! Here is the link to file your permit online. Starting October 1st ALL permits must be submitted
through the online portal. **
From: Andrew Nast <andrew@yourbrickandmortar.com>
Sent: Wednesday, December 20, 2023 7:00 AM
To: Kelsey Fawell <kfawell@lagrangeil.gov>
Cc: Charity Jones <cjones@lagrangeil.gov>; Daisy Cabrera <dcabrera@lagrangeil.gov>; Maureen Rush
<mrush@lagrangeil.gov>; Mike DeLillo <mdelillo@lagrangeil.gov>; Adam Clabaugh <adam@yourbrickandmortar.com>
Subject: Re: 30 S. La Grange Rd, La Grange | Restaurant Concept
Good morning Kelsey,
1
The restaurant would utilize ~2,200 sqft on the main level with coworking utilizing the remaining space on the
first floor and entirety of the second floor.
All the best,
Andrew Nast
MANAGING PARTNER
(847) 777 3808 main
mobile
CONFIDENTIAL COMMUNICATION: You are advised that this email may contain information, attachments, pictures, media, links,
or statements that are legally privileged. Delivery of this message to anyone other than the intended recipient(s) shall not serve as a
waiver of the attorney-client privilege or any confidentiality. If you have received this message in error, please notify the sender
immediately and delete this email, including any attachments, from your system.
--
On Mon, Dec 18, 2023 at 3:30 PM Kelsey Fawell <kfawell@lagrangeil.gov> wrote:
Hi Andrew,
Thanks for your email. Would the retail and coworking space be scrapped entirely? Would the space be entirely
devoted to a restaurant or will there be any other uses? Any additional information you could provide me so I can
assess to the special use permit is greatly appreciated.
Respectfully,
Kelsey Fawell
Village Planner
La Grange, IL 60525
PH: 708-579-2300 ext. 104
lagrangeil.gov
** Online permiting is now available! Here is the link to file your permit online. Starting October 1st ALL permits must be
submitted through the online portal. **

Sent: Monday, December 18, 2023 8:00 AM
To: Charity Jones <cjones@lagrangeil.gov>; Daisy Cabrera <dcabrera@lagrangeil.gov>; Maureen Rush
<mrush@lagrangeil.gov>; Mike DeLillo <mdelillo@lagrangeil.gov>; Kelsey Fawell <kfawell@lagrangeil.gov>
Cc: Adam Clabaugh <adam@yourbrickandmortar.com>
Subject: 30 S. La Grange Rd, La Grange | Restaurant Concept
2
[EXTERNAL EMAIL] Verify sender and use caution when opening attachments or clicking links
Good morning All,
At 30 S. La Grange Rd, La Grange—if we're considering adjusting course to move forward with a restaurant
concept on the majority of the first floor and frontage, how would this impact the special use permit and any
other requirements?
All the best,
Andrew Nast
MANAGING PARTNER
(847) 777 3808 main
mobile
CONFIDENTIAL COMMUNICATION: You are advised that this email may contain information, attachments, pictures, media,
links, or statements that are legally privileged. Delivery of this message to anyone other than the intended recipient(s) shall not serve
as a waiver of the attorney-client privilege or any confidentiality. If you have received this message in error, please notify the sender
--
This e-mail message is intended solely for the individuals to whom it is addressed. If you believe you received this e-mail in error, please notify the sender
immediately, delete the e-mail from your computer, and do not copy or disclose it to anyone else. Thank you.
The statements, opinions, and views expressed by the author in this message are the personal statements, opinions, and views of the author only, and they
should not be construed, deemed, or interpreted to be those of the Village of La Grange or any other elected or appointed official, officer, agent, or employee of
the Village of La Grange.
3
lagrangeil.gov
October 17, 2023
Adam Clabaugh
Andrew Nast
30 La Grange LLC
11 N Northwest Hwy, Suite 101
Park Ridge, IL 60068-0000
William Lundgren
55 W. Monroe St, Suite 3330
Chicago, IL 60603-5094
RE: 30 S. La Grange Road – Formal Notice of Code Violations and Courtesy Notice of Expiration
of Prior Approvals and Pending Applications
Messrs Clabaugh, Nast, and Lundgren:
The purpose of this letter is to advise you of the expiration of several prior approvals and
pending applications for 30 S. La Grange Road and to notify you of the required timeframe to
correct current code violations on the property.
Expiration of Prior Approvals and Pending Applications

On July 12, 2021, the Village Board of Trustees approved Ordinance O-21-11, granting a zoning
code text amendment, special use permit, site plan approval, and design review permit to
authorize co-working in conjunction with retail sales at 30 S. La Grange Road.
On April 7, 2022, a permit authorizing interior demolition only was issued pursuant to an
application dated April 4, 2022. On June 7, 2022, an application for fire alarm permit was
submitted; on June 8, 2022 Andrew Nast was advised that an application for a building permit
and an application for a fire sprinkler system permit were also required. On July 1, 2022, an
application for a building permit was submitted. To-date, no application has been submitted for
a fire sprinkler system permit.
Page 2
On July 15, 2022, plan review comments on the building permit application were provided to
the applicant; the review comments noted that the proposed plans did not conform to the
requirements of O-21-11 and requested information to clarify other proposed plan elements.
On August 23, 2022 an application to amend the Design Review Permit for 30 S. La Grange
Road was submitted; this application was approved on October 10, 2022 by Ordinance O-22-
17. No further permit submittals have been received to-date. The Village’s last correspondence
with Brick & Mortar was an email exchange between Michael DeLillo and Andrew Nast on
February 7, 2023 regarding a potential future submittal of the required fire sprinkler system
permit application.
Per Section 14-401I of the La Grange Zoning Code, subject to an extension of time granted by
the Village Manager pursuant to Subsection 13-101L of this Code, no special use permit shall
be valid for a period longer than one year, unless a building permit is issued and construction is
Certificate of Occupancy is issued and a use commenced within that period.
Per Section 14-402H of the La Grange Zoning Code, subject to an extension of time granted by
the Village Manager pursuant to Subsection 13-101L of this Code, no site plan approval shall be
valid for a period longer than one year unless a Building Permit is issued and construction is
Certificate of Zoning Compliance is issued and a use commenced within that period.
Per Section 14-403H of the La Grange Zoning Code, a Design Review Permit shall become null
and void six months after the date on which it was issued unless within such period the work
authorized by such certificate is commenced.
La Grange Building Code Section 150.09.B.5 establishes that any application for permit for any
proposed work shall be deemed to have been abandoned 180 days after the filing or date of
last action, unless the application has been pursued in good faith or a permit has been issued;
except the Building Official is authorized to grant an extension of time provided the request is
received in writing and justifiable cause is demonstrated.
As of the writing of this letter, it has been over two years since approval of the special use permit
and site plan for 30 S. La Grange Road granted in O-21-11, over one year since the approval of
the amended design review permit for 30 S. La Grange Road granted in O-22-17, and over six
months since the last correspondence related to pending building permit application(s) for 30
S. La Grange Road. Accordingly, this letter serves as a courtesy notice that all zoning approvals
granted by O-21-11 and O-22-17 are null and void and all pending building permit applications
are deemed abandoned.
Code Violations
After completing a survey October 17, 2023, it has been noted that the specified address above
currently violates the following codes (text in italics describes the current violations):
Page 3
• PM-301.3 Vacant structures and land. Vacant structures and premises thereof or vacant land
shall be maintained in a clean, safe, secure and sanitary condition as provided herein so as
not to cause a blighting problem or adversely affect the public health or safety. (Destroyed
menu box at the front of the building, broken tiles at front entrance, paper in windows)
• PM-302.3 Sidewalks and driveways. Sidewalks, walkways, stairs, driveways, parking spaces
and similar areas shall be kept in a proper state of repair, and maintained free from
hazardous conditions. (Deteriorated concrete at scupper rear going into the ground)
• PM-302.9 Defacement of property. No person shall willfully or wantonly damage, mutilate or

deface any exterior surface of any structure or building on any private or public property by
placing thereon any marking, carving or graffiti. It shall be the responsibility of the owner to
restore said surface to an approved state of maintenance and repair. (Graffiti at 2 rear
vestibules)
• PM-304.2 Protective treatment. Exterior surfaces, including but not limited to, doors, door
and window frames, cornices, porches, trim, balconies, decks and fences, shall be
maintained in good condition. Exterior wood surfaces, other than decay-resistant woods,
shall be protected from the elements and decay by painting or other protective covering or
treatment. Peeling, flaking and chipped paint shall be eliminated and surfaces repainted.
Siding and masonry joints, as well as those between the building envelope and the perimeter
of windows, doors and skylights, shall be maintained weather resistant and water tight. Metal
surfaces subject to rust or corrosion shall be coated to inhibit such rust and corrosion, and
surfaces with rust or corrosion shall be stabilized and coated to inhibit future rust and
corrosion. Oxidation stains shall be removed from exterior surfaces. Surfaces designed for
stabilization by oxidation are exempt from this requirement. (Tuck-pointing deteriorated out
the alley south west corner top of building, peeling paint south west corner bottom, peeling
paint windows at alley second-floor, tuck-pointing at front entrance deteriorated, peeling
paint with damaged substrate at front entrance, including window frames, de-laminated
concrete at alley wall. Please note, tuckpointing requires a permit.)
• PM-304.13 Window, skylight and door frames: Every window, skylight, door and frame shall
be kept in sound condition, good repair and weather tight. (Rusty rear door at west side)
• PM-304.5 Foundation walls: All foundation walls shall be maintained plumb and free from
open cracks and breaks and shall be kept in such condition so as to prevent the entry of
rodents and other pests. (Damaged foundation at dumpster.)
Please take this opportunity to correct the violations. A re-inspection of the property will be
made on or about November 17, 2023 in order to determine compliance. Should you not be
able to complete the aforementioned items in the requested timeframe, you must contact
Environmental Health Officer Curt Trusner to discuss an alternative timeframe. Should you have
any questions, please feel free to contact Mr. Trusner at 708-579-2320 X 105. Thank you for
your time and consideration on this matter.
Page 4
Sincerely,
Charity Jones, AICP

Deputy Village Manager / Community Development Director
708-579-2320
cjones@lagrangeil.gov
Maureen Rush

Sent: Tuesday, March 5, 2024 10:53 PM
To: Kelsey Fawell
Cc: Adam Clabaugh; John Kenney
Thank you, Kelsey.
Hi John, is there a good time this week when you're available for a call?
All the best,
Andrew Nast
MANAGING PARTNER
(847) 777 3808 main
( mobile
--
On Tue, Mar 5, 2024 at 5:23 PM Kelsey Fawell <kfawell@lagrangeil.gov> wrote:
Hi Andrew,
I hope you are well yourself. You’ll need to contact John Kenney, Village Prosecutor, at john@jfklegal.com to discuss
next steps. I’ve CC’ed John on this email for your convenience – please reach out to John directly.
Have a great evening,
Kelsey Fawell
Village Planner
La Grange, IL 60525
1
PH: 708-579-2300 ext. 104
lagrangeil.gov
** Online permitting is now available! Here is the link to file your permit online. Starting October 1st ALL permits must be

Hi Kelsey,
Hope you're doing well!
With many of the maintenance items wrapped up, are there any next steps we should be aware of on this
matter?
All the best,
Andrew Nast
MANAGING PARTNER
(847) 777 3808 main
mobile
2
--
On Fri, Dec 22, 2023 at 2:27 PM Kelsey Fawell <kfawell@lagrangeil.gov> wrote:
Hi Andrew,
The list of permitted and special uses allowed within the C‐1CR District, which 30 S. La Grange Rd. is zoned, can be
found within Article 5 of the Zoning Code. Per Section 5‐102, a restaurant use is permitted by‐right within the C‐1CR
District (no special use permit required). Office uses, such as the coworking you proposed, are only allowed as a
permitted use when not located on the ground floor within the C‐1CR District. Per Section 5‐105 of the Village Zoning
Code, coworking space on the first floor in conjunction with retail sales, subject to additional conditions, is a special
use within the C‐1CR District.
that need to be corrected and that any pending zoning application does not change the obligation to timely remedy
the outstanding violations. In addition to the remedies provided for elsewhere in Village Code, per Section 150.08(G)
of the Village Building Code, the village may withhold any permit, until outstanding violations has been resolved in
their entirety.
Kelsey Fawell
Village Planner
La Grange, IL 60525
3
PH: 708-579-2300 ext. 104
lagrangeil.gov

The restaurant would utilize ~2,200 sqft on the main level with coworking utilizing the remaining space on
the first floor and entirety of the second floor.
All the best,
Andrew Nast
MANAGING PARTNER
(847) 777 3808 main
mobile
links, or statements that are legally privileged. Delivery of this message to anyone other than the intended recipient(s) shall not
serve as a waiver of the attorney-client privilege or any confidentiality. If you have received this message in error, please notify the
sender immediately and delete this email, including any attachments, from your system.
--
4
Hi Andrew,
Respectfully,
Kelsey Fawell
Village Planner
La Grange, IL 60525
PH: 708-579-2300 ext. 104
lagrangeil.gov

Good morning All,
5
other requirements?
All the best,
Andrew Nast
MANAGING PARTNER
(847) 777 3808 main
( mobile
serve as a waiver of the attorney-client privilege or any confidentiality. If you have received this message in error, please notify
the sender immediately and delete this email, including any attachments, from your system.
--
should not be construed, deemed, or interpreted to be those of the Village of La Grange or any other elected or appointed official, officer, agent, or employee
of the Village of La Grange.
6
Maureen Rush
From: John Kenney <john@jfklegal.com>

Sent: Wednesday, March 6, 2024 7:56 AM
To: Andrew Nast; Kelsey Fawell
Cc: Adam Clabaugh
Mr. Nast:
A complaint was filed against 30 La Grange LLC in January, due to uncorrected Code violations. The
complaint was then served upon your registered agent. The matter is set for initial status before Judge
McHugh on Friday – the information relating to that is contained in the summons served upon your Agent.
I recommend you review the complaint and consider contacting counsel. If you would still like to have a
conference call after review, please advise of your availability this afternoon or tomorrow afternoon.
Sincerely,
John Kenney

Cc: Adam Clabaugh <adam@yourbrickandmortar.com>; John Kenney <john@jfklegal.com>
Thank you, Kelsey.
All the best,
Andrew Nast
MANAGING PARTNER
(847) 777 3808 main
mobile
--
1
Hi Andrew,
I hope you are well yourself. You’ll need to contact John Kenney, Village Prosecutor, at john@jfklegal.com to discuss
next steps. I’ve CC’ed John on this email for your convenience – please reach out to John directly.
Kelsey Fawell
Village Planner
La Grange, IL 60525
PH: 708-579-2300 ext. 104
lagrangeil.gov
** Online permitting is now available! Here is the link to file your permit online. Starting October 1st ALL permits must be

Hi Kelsey,
With many of the maintenance items wrapped up, are there any next steps we should be aware of on this
matter?
All the best,
Andrew Nast
MANAGING PARTNER
(847) 777 3808 main
mobile
--

Hi Andrew,
2
The list of permitted and special uses allowed within the C‐1CR District, which 30 S. La Grange Rd. is zoned, can be
found within Article 5 of the Zoning Code. Per Section 5‐102, a restaurant use is permitted by‐right within the C‐1CR
District (no special use permit required). Office uses, such as the coworking you proposed, are only allowed as a
permitted use when not located on the ground floor within the C‐1CR District. Per Section 5‐105 of the Village Zoning
Code, coworking space on the first floor in conjunction with retail sales, subject to additional conditions, is a special
use within the C‐1CR District.
that need to be corrected and that any pending zoning application does not change the obligation to timely remedy
the outstanding violations. In addition to the remedies provided for elsewhere in Village Code, per Section 150.08(G)
of the Village Building Code, the village may withhold any permit, until outstanding violations has been resolved in
their entirety.
Kelsey Fawell
Village Planner
La Grange, IL 60525
PH: 708-579-2300 ext. 104
lagrangeil.gov
The restaurant would utilize ~2,200 sqft on the main level with coworking utilizing the remaining space on
the first floor and entirety of the second floor.
All the best,
Andrew Nast
MANAGING PARTNER
(847) 777 3808 main
( mobile
serve as a waiver of the attorney-client privilege or any confidentiality. If you have received this message in error, please notify the
sender immediately and delete this email, including any attachments, from your system.
3
--

Hi Andrew,
Respectfully,
Kelsey Fawell
Village Planner
La Grange, IL 60525
PH: 708-579-2300 ext. 104
lagrangeil.gov
Good morning All,
other requirements?
All the best,
Andrew Nast
MANAGING PARTNER
(847) 777 3808 main
mobile
serve as a waiver of the attorney-client privilege or any confidentiality. If you have received this message in error, please notify
the sender immediately and delete this email, including any attachments, from your system.
4
--
should not be construed, deemed, or interpreted to be those of the Village of La Grange or any other elected or appointed official, officer, agent, or employee
of the Village of La Grange.
5
Maureen Rush

To: John Kenney
Cc: Kelsey Fawell; Adam Clabaugh; William Lundgren
Thank you, John. Would you mind sharing a copy of the summons?
Looping in our attorney Bill Lundgren so we’re all on the same page.
All the best,
Andrew Nast
MANAGING PARTNER
(847) 777 3808 main
( mobile
CONFIDENTIAL COMMUNICATION: You are advised that this email may contain information, attachments,
pictures, media, links, or statements that are legally privileged. Delivery of this message to anyone other than
the intended recipient(s) shall not serve as a waiver of the attorney-client privilege or any confidentiality. If you
have received this message in error, please notify the sender immediately and delete this email, including any
attachments, from your system.
--
On Mar 6, 2024, at 7:55 AM, John Kenney <john@jfklegal.com> wrote:
Mr. Nast:
A complaint was filed against 30 La Grange LLC in January, due to uncorrected Code
violations. The complaint was then served upon your registered agent. The matter is set for
initial status before Judge McHugh on Friday – the information relating to that is contained in the
summons served upon your Agent.
I recommend you review the complaint and consider contacting counsel. If you would still
like to have a conference call after review, please advise of your availability this afternoon or
tomorrow afternoon.
1
Sincerely,
John Kenney

Thank you, Kelsey.
All the best,
Andrew Nast
MANAGING PARTNER
(847) 777 3808 main
( mobile
pictures, media, links, or statements that are legally privileged. Delivery of this message to anyone other than the
intended recipient(s) shall not serve as a waiver of the attorney-client privilege or any confidentiality. If you have
received this message in error, please notify the sender immediately and delete this email, including any
--
Hi Andrew,
I hope you are well yourself. You’ll need to contact John Kenney, Village Prosecutor, at
john@jfklegal.com to discuss next steps. I’ve CC’ed John on this email for your convenience – please
reach out to John directly.
Kelsey Fawell
Village Planner
2
La Grange, IL 60525
PH: 708-579-2300 ext. 104
lagrangeil.gov
** Online permitting is now available! Here is the link to file your permit online. Starting October 1st ALL permits
must be submitted through the online portal. **

Hi Kelsey,
With many of the maintenance items wrapped up, are there any next steps we should be aware
of on this matter?
All the best,
Andrew Nast
MANAGING PARTNER
(847) 777 3808 main
( mobile
3
--
Hi Andrew,
Thank you for providing additional information regarding the proposed use of 30 S. La Grange Road.
The property’s previously granted special use permit is expired. A detailed notice regarding code
violations and expiration of prior approvals/applications is attached for your convenience; dated and
sent to you on October 17, 2023.
The list of permitted and special uses allowed within the C‐1CR District, which 30 S. La Grange Rd. is
zoned, can be found within Article 5 of the Zoning Code. Per Section 5‐102, a restaurant use is
permitted by‐right within the C‐1CR District (no special use permit required). Office uses, such as the
coworking you proposed, are only allowed as a permitted use when not located on the ground floor
within the C‐1CR District. Per Section 5‐105 of the Village Zoning Code, coworking space on the first
floor in conjunction with retail sales, subject to additional conditions, is a special use within the C‐1CR
District.
I will also take this time to remind you of the outstanding property maintenance and code violations
on the property that need to be corrected and that any pending zoning application does not change
the obligation to timely remedy the outstanding violations. In addition to the remedies provided for
elsewhere in Village Code, per Section 150.08(G) of the Village Building Code, the village may withhold
any permit, until outstanding violations has been resolved in their entirety.
4
Kelsey Fawell
Village Planner
La Grange, IL 60525
PH: 708-579-2300 ext. 104
lagrangeil.gov
** Online permiting is now available! Here is the link to file your permit online. Starting October 1st ALL permits

<mrush@lagrangeil.gov>; Mike DeLillo <mdelillo@lagrangeil.gov>; Adam Clabaugh
<adam@yourbrickandmortar.com>
The restaurant would utilize ~2,200 sqft on the main level with coworking utilizing
the remaining space on the first floor and entirety of the second floor.
All the best,
Andrew Nast
MANAGING PARTNER
(847) 777 3808 main
( mobile
5
--
Hi Andrew,
Thanks for your email. Would the retail and coworking space be scrapped entirely? Would the space
be entirely devoted to a restaurant or will there be any other uses? Any additional information you
could provide me so I can assess to the special use permit is greatly appreciated.
Respectfully,
Kelsey Fawell
Village Planner
La Grange, IL 60525
PH: 708-579-2300 ext. 104
lagrangeil.gov
** Online permiting is now available! Here is the link to file your permit online. Starting October 1st ALL
permits must be submitted through the online portal. **

To: Charity Jones <cjones@lagrangeil.gov>; Daisy Cabrera <dcabrera@lagrangeil.gov>; Maureen
Rush <mrush@lagrangeil.gov>; Mike DeLillo <mdelillo@lagrangeil.gov>; Kelsey Fawell
<kfawell@lagrangeil.gov>
6
[EXTERNAL EMAIL] Verify sender and use caution when opening attachments or clicking
links
Good morning All,
At 30 S. La Grange Rd, La Grange—if we're considering adjusting course to move forward

with a restaurant concept on the majority of the first floor and frontage, how would this
impact the special use permit and any other requirements?
All the best,
Andrew Nast
MANAGING PARTNER
(847) 777 3808 main
mobile
intended recipient(s) shall not serve as a waiver of the attorney-client privilege or any confidentiality. If you
--
This e-mail message is intended solely for the individuals to whom it is addressed. If you believe you received this e-mail in error, please
notify the sender immediately, delete the e-mail from your computer, and do not copy or disclose it to anyone else. Thank you.
The statements, opinions, and views expressed by the author in this message are the personal statements, opinions, and views of the
author only, and they should not be construed, deemed, or interpreted to be those of the Village of La Grange or any other elected or
appointed official, officer, agent, or employee of the Village of La Grange.
7
Maureen Rush

To: Andrew Nast
Andrew,
Mr. Lundgren should have a copy.
JMK

To: John Kenney <john@jfklegal.com>
Cc: Kelsey Fawell <kfawell@lagrangeil.gov>; Adam Clabaugh <adam@yourbrickandmortar.com>; William Lundgren
<wlundgren@zabellaw.com>
All the best,
Andrew Nast
MANAGING PARTNER
(847) 777 3808 main
mobile
--
1
Mr. Nast:
tomorrow afternoon.
Sincerely,
John Kenney

Thank you, Kelsey.
All the best,
Andrew Nast
MANAGING PARTNER
(847) 777 3808 main
( mobile
--

Hi Andrew,
2
Kelsey Fawell
Village Planner
La Grange, IL 60525
PH: 708-579-2300 ext. 104
lagrangeil.gov

Hi Kelsey,
of on this matter?
All the best,
Andrew Nast
MANAGING PARTNER
(847) 777 3808 main
( mobile
--

Hi Andrew,
3
District.
Kelsey Fawell
Village Planner
La Grange, IL 60525
PH: 708-579-2300 ext. 104
lagrangeil.gov
All the best,
Andrew Nast
MANAGING PARTNER
(847) 777 3808 main
( mobile
--
4
Hi Andrew,
Respectfully,
Kelsey Fawell
Village Planner
La Grange, IL 60525
PH: 708-579-2300 ext. 104
lagrangeil.gov
links
Good morning All,

All the best,
Andrew Nast
MANAGING PARTNER
(847) 777 3808 main
mobile
5
--
6
Maureen Rush

To: John Kenney
Of course. Thank you, John.
All the best,
Andrew Nast
MANAGING PARTNER
(847) 777 3808 main
mobile
--
Andrew,
JMK

Cc: Kelsey Fawell <kfawell@lagrangeil.gov>; Adam Clabaugh <adam@yourbrickandmortar.com>;
William Lundgren <wlundgren@zabellaw.com>
1
All the best,
Andrew Nast
MANAGING PARTNER
(847) 777 3808 main
( mobile
CONFIDENTIAL COMMUNICATION: You are advised that this email may contain
information, attachments, pictures, media, links, or statements that are legally privileged.
Delivery of this message to anyone other than the intended recipient(s) shall not serve as a
waiver of the attorney-client privilege or any confidentiality. If you have received this message
in error, please notify the sender immediately and delete this email, including any attachments,
from your system.
--
Mr. Nast:
A complaint was filed against 30 La Grange LLC in January, due to uncorrected

Code violations. The complaint was then served upon your registered
agent. The matter is set for initial status before Judge McHugh on Friday –
the information relating to that is contained in the summons served upon your
Agent.
I recommend you review the complaint and consider contacting counsel. If

you would still like to have a conference call after review, please advise of your
availability this afternoon or tomorrow afternoon.
Sincerely,
John Kenney

2
Cc: Adam Clabaugh <adam@yourbrickandmortar.com>; John Kenney
<john@jfklegal.com>
Thank you, Kelsey.
All the best,
Andrew Nast
MANAGING PARTNER
(847) 777 3808 main
mobile
information, attachments, pictures, media, links, or statements that are legally privileged. Delivery
of this message to anyone other than the intended recipient(s) shall not serve as a waiver of the
attorney-client privilege or any confidentiality. If you have received this message in error, please
notify the sender immediately and delete this email, including any attachments, from your system.
--
Hi Andrew,
john@jfklegal.com to discuss next steps. I’ve CC’ed John on this email for your
convenience – please reach out to John directly.
Kelsey Fawell
Village Planner
<image003.png> 53 S. La Grange Road
La Grange, IL 60525
PH: 708-579-2300 ext. 104
lagrangeil.gov
3
** Online permitting is now available! Here is the link to file your permit online. Starting
October 1st ALL permits must be submitted through the online portal. **

Hi Kelsey,
With many of the maintenance items wrapped up, are there any next steps we
should be aware of on this matter?
All the best,
Andrew Nast
MANAGING PARTNER
(847) 777 3808 main
mobile
Delivery of this message to anyone other than the intended recipient(s) shall not serve as a waiver
of the attorney-client privilege or any confidentiality. If you have received this message in error,
please notify the sender immediately and delete this email, including any attachments, from your
system.
4
--
On Fri, Dec 22, 2023 at 2:27 PM Kelsey Fawell <kfawell@lagrangeil.gov>

wrote:
Hi Andrew,
Thank you for providing additional information regarding the proposed use of 30 S. La
Grange Road. The property’s previously granted special use permit is expired. A
detailed notice regarding code violations and expiration of prior
approvals/applications is attached for your convenience; dated and sent to you on
October 17, 2023.
The list of permitted and special uses allowed within the C‐1CR District, which 30 S. La
Grange Rd. is zoned, can be found within Article 5 of the Zoning Code. Per Section 5‐
102, a restaurant use is permitted by‐right within the C‐1CR District (no special use
permit required). Office uses, such as the coworking you proposed, are only allowed
as a permitted use when not located on the ground floor within the C‐1CR District. Per
Section 5‐105 of the Village Zoning Code, coworking space on the first floor in
conjunction with retail sales, subject to additional conditions, is a special use within
the C‐1CR District.
I will also take this time to remind you of the outstanding property maintenance and
code violations on the property that need to be corrected and that any pending
zoning application does not change the obligation to timely remedy the outstanding
violations. In addition to the remedies provided for elsewhere in Village Code, per
Section 150.08(G) of the Village Building Code, the village may withhold any permit,
until outstanding violations has been resolved in their entirety.
Don’t hesitate to contact me with any additional questions. Enjoy the upcoming
Holidays,
Kelsey Fawell
Village Planner
<image002.png>
5
La Grange, IL 60525
PH: 708-579-2300 ext. 104
lagrangeil.gov
** Online permiting is now available! Here is the link to file your permit online. Starting

Cc: Charity Jones <cjones@lagrangeil.gov>; Daisy Cabrera <dcabrera@lagrangeil.gov>;
Maureen Rush <mrush@lagrangeil.gov>; Mike DeLillo <mdelillo@lagrangeil.gov>;
Adam Clabaugh <adam@yourbrickandmortar.com>
The restaurant would utilize ~2,200 sqft on the main level with coworking
utilizing the remaining space on the first floor and entirety of the second floor.
All the best,
Andrew Nast
MANAGING PARTNER
(847) 777 3808 main
mobile
waiver of the attorney-client privilege or any confidentiality. If you have received this message
6
in error, please notify the sender immediately and delete this email, including any attachments,
from your system.
--
On Mon, Dec 18, 2023 at 3:30 PM Kelsey Fawell <kfawell@lagrangeil.gov>

wrote:
Hi Andrew,
Thanks for your email. Would the retail and coworking space be scrapped entirely?
Would the space be entirely devoted to a restaurant or will there be any other uses?
Any additional information you could provide me so I can assess to the special use
permit is greatly appreciated.
Respectfully,
Kelsey Fawell
Village Planner
<image002.png> 53 S. La Grange Road
La Grange, IL 60525
PH: 708-579-2300 ext. 104
lagrangeil.gov
** Online permiting is now available! Here is the link to file your permit online. Starting

To: Charity Jones <cjones@lagrangeil.gov>; Daisy Cabrera
<dcabrera@lagrangeil.gov>; Maureen Rush <mrush@lagrangeil.gov>; Mike DeLillo
<mdelillo@lagrangeil.gov>; Kelsey Fawell <kfawell@lagrangeil.gov>
7
[EXTERNAL EMAIL] Verify sender and use caution when opening attachments
or clicking links
Good morning All,
At 30 S. La Grange Rd, La Grange—if we're considering adjusting course to

move forward with a restaurant concept on the majority of the first floor and
frontage, how would this impact the special use permit and any other
requirements?
All the best,
Andrew Nast
MANAGING PARTNER
(847) 777 3808 main
mobile
waiver of the attorney-client privilege or any confidentiality. If you have received this
message in error, please notify the sender immediately and delete this email, including any
--
This e-mail message is intended solely for the individuals to whom it is addressed. If you believe you received this
e-mail in error, please notify the sender immediately, delete the e-mail from your computer, and do not copy or
disclose it to anyone else. Thank you.
The statements, opinions, and views expressed by the author in this message are the personal statements,
opinions, and views of the author only, and they should not be construed, deemed, or interpreted to be those of the
8
Village of La Grange or any other elected or appointed official, officer, agent, or employee of the Village of La
Grange.
9
Maureen Rush
From: William Lundgren <wlundgren@zabellaw.com>

To: John Kenney; Andrew Nast
Cc: Kelsey Fawell; Adam Clabaugh
Subject: RE: 30 S. La Grange Rd, La Grange | Restaurant Concept
Good morning Mr. Kenney,
Would it be possible to schedule a quick call this afternoon to discuss the above mentioned matter? If that is acceptable,
please provide me with your availability and contact number.
William B. Lundgren
Attorney at Law
Zabel Law, LLC
55 West Monroe, Suite 3330
Chicago, Illinois 60603
Office Ph: 312-201-9800 Ext. 243
Direct Ph: 312-380-2470
Fax: 312-201-1436
Zabel Law, LLC will no longer be delivering wire instructions. If you receive wire instructions from anyone at our firm,
please notify us immediately. All wire instructions must be obtained by the Purchaser directly from the title company or
lender. Never initiate a wire without first calling to confirm the wire instructions.

To: Andrew Nast <andrew@yourbrickandmortar.com>
Andrew,
JMK

1
All the best,
Andrew Nast
MANAGING PARTNER
(847) 777 3808 main
mobile
--
Mr. Nast:
tomorrow afternoon.
Sincerely,
John Kenney

Thank you, Kelsey.

2
All the best,
Andrew Nast
MANAGING PARTNER
(847) 777 3808 main
mobile
--

Hi Andrew,
Kelsey Fawell
Village Planner
La Grange, IL 60525
PH: 708-579-2300 ext. 104
lagrangeil.gov

Hi Kelsey,
3
of on this matter?
All the best,
Andrew Nast
MANAGING PARTNER
(847) 777 3808 main
--

Hi Andrew,
District.
4
Kelsey Fawell
Village Planner
La Grange, IL 60525
PH: 708-579-2300 ext. 104
lagrangeil.gov
All the best,
Andrew Nast
MANAGING PARTNER
(847) 777 3808 main
( mobile
--

Hi Andrew,
Respectfully,
5
Kelsey Fawell
Village Planner
La Grange, IL 60525
PH: 708-579-2300 ext. 104
lagrangeil.gov
links
Good morning All,

All the best,
Andrew Nast
MANAGING PARTNER
(847) 777 3808 main
( mobile
--

La Grange Issues With 30 S. La Grange Road

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La Grange Issues With 30 S. La Grange Road

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LAGRANGE

RESPONSE TO REQUEST FOR PU BLI C RECO RDS

To: Patch .com

Subject to payment of any required fees or postage pursuant to Section 4 or 5 below,

March 27, 2024

From : David Giuliani <david.giuliani@patch .com>

Follow Up Flag: Follow up

This is a public records request under the Freedom of Information Act.

October 17, 2023

Messrs Clabaugh, Nast, and Lundgren:

Expiration of Prior Approvals and Pending Applications

• PM-302.9 Defacement of property. No person shall willfully or wantonly damage, mutilate or

Charity Jones, AICP

VILLAGE OF LA GRANGE, an Illinois )

SUIT TO ENFORCE POLTCE POWER _ COMPLAINT FOR FINE, DEMOLITION,

NOW COMES the Plaintiff, VILLAGE OF LAGRANGE, a municipal corporation, by

COUNT I _ INJUNCTIVE RELIEF

l. PlaintiffVillage of La Grange ("LA GRANGE") is a municipal corporation located in the

County of Cook, State of Illinois.

2. Defendant 30 LA GRANGE LLC("OWNER") is the record owner of the property

Grange, County of Cook. State of lllinois.

3. Defendant PARK RIDGE COMMUNITY BANK ("PARK RIDGE") is the holder of a

mortgage upon the Property.

description of "LTNKNOWN OWNERS', 'UNKNOWN OCCUPANTS" and "NONRECORD

order or decree entered herein.

6. 65 ILCS 5/11-31-1 provides in part that if a structure contains an emergency or incurable

board-up said structure.

under such terms and conditions as will do justice.

GRANGE CODE provided as follou's:

GRANGE Code of Ordinances provided as follows:

PM-302.3 Sidewalks and Driveways. All sidewalks, walkways, stairs, driveways,

concrete at the rear scupper.

GRANGE CODE provided as follows:

PM-302.9 Defacement of Property. No person shall wilfully or wantonly damage,

graffiti at the two (2) rear vestibules.

GRANGE CODE provided as follows:

304.2 Protective treatment

and delaminated concrete at alley wall.

GRANGE CODE provided as follows:

304.13 Window, skllight and door frames

the rusty rear west side door.

GRANGE CODE provided as follows:

damaged foundation at the dumpster.

violationofSections5/11-31-15,5/ll-31-1 and 5/ll-31-2 ofChapter 65 ofthe Illinois Municipal

24. That the violations alleged herein exist currently.

unsafe, and unhealthy.

27 . LA GRANGE has no adequate remedy at law'. Its purpose by this Complaint is to

WHEREFORE, Plaintiffprays. pursuant to LA GRANGE Code Sections 301.3, 302.3, 302.9,

COTINT II _ VIOLATION OF LA GRANGE CODE _ FINES AND PENALTIES

Count I as Paragraphs One through Twenty Seven of Count II.

28. The aforementioned violations of LA GRANGE CODE. constitute continuous, ongoing

302.3,302.9.304.2.304.13. and 304.5 of the LA GRANGE CODE.

lsl John M. Kenney

One of Its Attorneys

Subscribed and Swom to before me

From: Kelsey Fawell <kfawell@lagrangeil.gov>

Good morning Kelsey,

All the best,

On Mon, Dec 18, 2023 at 3:30 PM Kelsey Fawell <kfawell@lagrangeil.gov> wrote: