10 12 13 14 Is 16 7 18 19 20 2b 2 23 24 FILED Electronical Cvi0-0108: 2019-05-25 03:03:58 PM Jacqueline Bryant $3550 Transecon #1260088" yale RICHARD G. CAMPBELL, JR. eae Nevada Bar No. 1832 SEVERIN A. CARLSON: Nevada Bar No, 9373 KAEMPFER CROWELL 50 West Liberty St, Suite 700 Reno, Nevada 89501 Telephone: (775) 852-3900 Fax (775) 327-2011 reampbell@kenvlaw.com scarlson@kenvlaw.com Attorneys for Petitioners, INTERNATIONAL COMMUNITY OF CHRIST, CHURCH OF THE SECOND ADVENT; and ST. THOMAS AQUINAS CATHOLIC CATHEDRAL CORPORATION IN THE SECOND JUDICIAL DISTRICT COURT OF THE STATE OF NEVADA. IN AND FOR THE COUNTY OF WASHOE INTERNATIONAL COMMUNITY OF ‘Case No,: CHRIST, CHURCH OF THE SECOND ADVENT, a Nevada non-profit corporation; | Dept. No.: and ST. THOMAS AQUINAS CATHOLIC CATHEDRAL CORPORATION, a Nevada non-profit organization, PETITION FOR JUDICIAL REVIEW ‘(Exempt from Arbitration - Action Seeking review of Administrative Petitioners, Decision) CITY OF RENO, a political subdivision of the State of Nevada, Respondent, Petitioners, INTERNATIONAL COMMUNITY OF CHRIST, CHURCH OF THE SECOND ADVENT (“International Community of Christ"), and ST, THOMAS AQUINAS CATHOLIC CATHEDRAL CORPORATION (“Saint Thomas Aquinas” and, together with International Community of Christ, collectively referred to herein as the “Petitioners”, by and Page 1 of 510 uw 12 B 14 16 17 19 20 a 22 23 24 through their counsel, Kaempfer Crowell, pursuant to NRS 271.395, hereby petition this Court for Judicial Review of the Decision issued by the Reno City Council on May 8, 2019 (the cision”) with respect to the Downtown Reno Business Improvement District (“BID”) and passage of the proposed Resolution and Ordinance related thereto. True and correct copies of the proposed Resolution and Ordinance, which were ultimately passed on May 8, 2019 by the Reno City Council, are attached hereto as Exhibits 1 and 2, respectively. In support of the Petition for Judicial Review, Petitioners set forth the following: 1. Petitioners received a proposed Assessment Notice from the City of Reno for the Downtown Reno Business Improvement District and Notice of Hearing on such matter, which was set for May 8, 2019. 2. On May 3, 2019, International Community of Christ sent a letter of protest to the City of Reno Clerk setting forth several grounds objecting to the proposed assessment, including @ violation of assessing a property tax on a tax exempt organization. A copy of that letter of protest is attached as Exhibit 3 3. On May 2, 2019, Saint Thomas Aquinas sent a letter of protest to the City of Reno Clerk objecting to the proposed assessment on several grounds including that the assessment was a violation of imposing a tax on a tax exempt organization. A copy of that letter of protest is attached as Exhibit 4. 4. At the City of Reno hearing on May 8, 2019, the City Council denied the protests of the Petitioners and approved the Resolution and Ordinance, Petitioners seek judicial review of the Decision under the provisions of NRS 271.395 and more specifically, that tae Decision was (@) In violation of constitutional or statutory provisions; (b) In excess of the statutory authority of the City of Reno; Page 2 of S10 nN 13 14 15 16 7 19 20 21 23 24 (©) Made upon unlawful procedure; (@) Affected by other error of law; (©) Clearly erroneous in view of the reliable, probative and substantial evidence on the whole record; or ( Arbitrary or capricious or characterized by abuse of discretion. PRAYER FOR RELIEF WHEREFORE, Petitioners pray for judgment as follows: 1. That this Court grant judicial review of the Decision of the Reno City Council in passing the Resolution and Ordinance regarding the BID; 2. ‘That the Court vacate and set aside the Decision of the Reno City Council regarding the BID as to Petitioners; 3. For such other and further relief that this Court may deem just and proper; and 4, For any other general or specific relief as this Court may deem fair and equitable. w W We a i We a a a a ji Page 3 of 5 i