HomeMy WebLinkAboutGoodwin- Maune Court Case 101424ELECTRONICALLY FILED
Pulaski County Circuit Court,
Terri Hollingsworth, Circuit/County Clerk
2024-Oct-09 15:25:14
60CV-24-8746
C06D16 : 32 Pages
IN THE CIRCUIT COURT OF PULASKI COUNTY, ARKANSAS
DIVISION
BOBBY WILKERSON, Individually and as Trustee of PLAINTIFFS
THE BOBBY GLEN WILKERSON REVOCABLE
TRUST; TOM AND JENNIFER BURNETT, Individually
and as Trustees of THE TOM AND JENNIFER
BURNETT FAMILY TRUST; BRENT MEDDERS,
Individually and as Trustee of THE BRENT JULIAN
MEDDERS REVOCABLE TRUST; JACK AND
WHITNEY BOWER; MICHAEL AND KRISTY SPANN,
Individually and as Trustees of THE KRISTY'D. SPANN
REVOCABLE TRUST; and KEITH AND BISHAWN MORRIS
VS. CASE NO.:
GARY GOODWIN; ANDREA GOODWIN; and
JENNIFER MAUVE DEFENDANTS
VERIFIED COMPLAINT FOR BIMEDIATE TEMPORARY AND
PERMANENT INJUNCTIVE RELIEF
Plaintiffs, by and through counsel, for their Verified Complaint for Immediate,
Temporary and Permanent Injunctive Relief against Defendants, state:
Immediate Injunctive Relief is Needed
1. Plaintiffs are property owners and neighbors to Defendants Gary and Andrea
Goodwin in a residential area in rural, western Pulaski County.
2. Within the past few months, Defendants Gary and Andrea Goodwin have hosted
public events at their home for business or commercial purposes, which is in direct
violation of the restrictive covenants that apply to the residential development and the
City of Little Rock zoning restrictions.
3. Defendants Gary and Andrea Goodwin submitted a re -zoning application in 2020,
which was denied by the Little Rock Planning Commission. They appealed and their
appeal was likewise denied by the Little Rock City Board.
4. By virtue of their 2020 application for re -zoning, Defendants Gary and Andrea
Goodwin were seeking approval from the City to convert the residential zoning to a
planned commercial development. The Goodwins specifically intended to operate an
event center at their home whereby they would host more than 10 events annually for up
to 200 people with catering, music and alcohol.
5. Despite knowing that hosting such an event is a direct violation of the restrictive
covenants and zonizxg restrictions applicable to their property, Defendants Gary and
Andrea Goodwin have defiantly hosted events over the past few months. This is
particularly troubling given the fact that the City of Little Rock explicitly denied their
request to operate a business or commercial activity.
6. Plaintiffs have learned that the Goodwins intend to host another event on October
26, 2024.
7. The events being held by the Goodwin defendants wreak havoc on the Plaintiffs
and other surrounding property owners. The music echoes and reverberates through the
mountains and valleys of the neighbors `til late into the night. The commercial delivery
trucks and the traffic from the attending guests clog the roadway. The attendees of the
events drink alcohol and drive back out down a narrow and curvy roadway, risking injury
to both person and property.
8. The events create a nuisance to the Plaintiffs and the surrounding property
owners.
2
9. The events disturb the Plaintiffs' quiet enjoyment of their property.
10. The restrictive covenants that are applicable to Defendants Gary and Andrea
Goodwins' property states: "Any Lot Owner shall have the right to sue for and obtain an
injunction, preventative or mandatory, to prevent the breach of or to enforce the
observance of any covenants, agreements, or restrictions contained herein..."
11. Money damages cannot compensate Plaintiffs for the nuisance they endure nor for
the disturbance of the quiet enjoyment of their property. Likewise, money damages are
inadequate to address Defendants' violations of the restrictive covenants and zoning
restrictions.
12. Plaintiffs should be granted and they hereby respectfully request an immediate,
temporary and permanent injunction that prohibits Defendants from hosting events at
their home and property.
Parties to the Case
13, Plaintiff Bobby Wilkerson ("Wilkerson") is an individual and resident of Little
Rock, Pulaski County, Arkansas. Wilkerson is also the Trustee of the Bobby Glen
Wilkerson Revocable Trust. Wilkerson and his trust own a mountain top lot located in
the same residential community (Goodwin Estates) as Defendants Gary and Andrea
Goodwin's property.
14. Plaintiffs Tom and Jennifer Burnett (the `Burnetts"), a married couple, are
individuals and residents of Little Rock, Pulaski County, Arkansas. The Burnetts are also
trustees of the Tom and Jennifer Burnett Family Trust. The Burnetts and their trust own
land and reside on property that is adjacent to or nearby the property of Defendants Gary
and Andrea Goodwin.
15. Plaintiff Brent Medders (the "Medders"), is an individual and resident of Little
Rock, Pulaski County, Arkansas. Medders is also trustee of the Brent Julian Medders
Revocable Trust. Medders and his trust own land and reside on property that is adjacent
to or nearby the property of Defendants Gary and Andrea Goodwin.
16. Plaintiffs Jack and Whitney Bower (the "Bowers"), a married couple, are
individuals and residents of Little Rock, Pulaski County, Arkansas. The Bowers own
land and reside on property that is adjacent to or nearby the property of Defendants Gary
and Andrea Goodwin.
17. Plaintiffs Michael and Kristy Spann (the "Spann"), a married couple, are
individuals and residents of Little Rock, Pulaski County, Arkansas. The Spann are also
trustees of the Kristy D. Spann Revocable Trust. The Spanns and their trust own land
and reside on property that is adjacent to or nearby the property of Defendants Gary and
Andrea Goodwin.
18. Keith and Bishawn Morris (the "Morris's"), a married couple, are individuals and
residents of Little Rock, Pulaski County, Arkansas. The Morris's and their trust own
land and reside on property that is adjacent to or nearby the property of Defendants Gary
and Andrea Goodwin.
19. Defendants Gary Goodwin and Andrea Goodwin (the "Goodwins"), a married
couple, are individuals and residents of Little Rock, Pulaski County, Arkansas.
20. Defendant Jennifer Maune ("Maune") is an individual and resident of Little Rock,
Pulaski County, Arkansas. Maune is attempting to purchase the Goodwins' property to
both reside and to host events.
21. Jurisdiction and venue are proper with this court.
n
22. The Goodwins own a home and property located at 3709 Garrison Road, Little
Rock, Arkansas. The property is commonly referred to as Goodwin Manor-
23. The Goodwin property is zoned R-2, as single family residential.
24. Being zoned R-2, the Goodwins property is not permitted to be used for any
business or commercial purpose.
25. The Goodwin property is surrounded by neighboring residential property and
homes, with no commercial operations or businesses nearby.
26. The Goodwin property is also subject to a set of restrictive covenants. A copy of
the Declaration of Covenants, Restrictions, Easements, Charges and Liens for Goodwin
Estates is attached hereto as Exhibit "A" and incorporated herein by reference.
27. The Declaration of Covenants (Exhibit "A") specifically prohibits any business or
commercial use in or on the property of the Goodwin. See paragraph 2 of Exhibit "A".
28. Despite being zoned R-2 and being subject to the Declaration of Covenants, the
Goodwin have operated an event center at the property on numerous occasions.
29. The events hosted by the Goodwin have included weddings, large dinner parties
and other events whereby up to 200 people have attended.
30. The events have been catered and sometimes have a live band or loud music
playing.
d that they host the events; at least in part, to offset the
31. The Goodwin have state
expense of the home and property. Thus, the Goodwins are operating the event center at
their property for income and revenue generating purposes.
32. The events allow drinking of alcohol, which has led to guests of the Goodwin
drinking and driving at night. On one occasion, a drunk driver hit the fence of one of the
neighboring homes.
33. After one of the Goodwin's events, a commercial delivery driver woke the Spanns
up at midnight while trying to find the Goodwin's property to pick up flowers and
arrangements.
34. The Plaintiffs are disturbed by the loud music emanating from the events held at
the Goodwin's property til late .in the night.
35. The lights from the Goodwin events disturb the Plaintiffs' view of the night sky,
which is normally free of light pollution but for the Goodwin's events.
36. The traffic from commercial delivery trucks and dozen if not hundreds of
attendees of the events disturbs Plaintiffs peaceful and quiet enjoyment of their property.
37. Just this past Saturday morning, an EMS vehicle and fire truck showed up at one
of the neighbors' homes trying to get to. the Goodwin's property.
38. Despite the Goodwins having their 2020 re -zoning application denied, the
Goodwin and Defendant Maune have recently jointly applied again for re -zoning the
residential property as a planned commercial development. A copy of their letter dated
August 11, 2024 is attached as Exhibit "B" and incorporated herein by reference.
Count I — Violation of Restrictive Covenants
39. The restrictive covenants that for the Goodwin's property limits the property's use
to single-family, residential homes only. See paragraph 2, Exhibit "A".
40. Further, the restrictive covenants explicitly prohibit any business or commercial
use of the property. See paragraph 2, Exhibit "A".
2
41. Ironically, the Goodwin's created the restrictive covenants — only to intentionally
violate them.
42. The restrictive covenants mandates that any lot owner shall have the right to sue
for and obtain an injunction to prevent a breach or to enforce the observance of the
covenants and restrictions. See paragraph 11, Exhibit "X'.
43. Plaintiff Wilkerson owns property in the same residential development as the
Goodwins and is subject to the same restrictive covenants. Wilkerson purchased the land
from Jack Hartsell, who purchased the land from the Goodwin.
44. Plaintiffs, and specifically, Plaintiff Wilkerson, respectfully request and are
entitled to an immediate, temporary and permanent injunction that would enjoin
Defendants from hosting events at the property and from otherwise violating the
restrictive covenants.
Count II — Violation of Zoning Restrictions
45. The Goodwin's property is located within the extra -territorial jurisdiction of the
City of Little Rock and is subject to the zoning requirements thereof.
46. The Goodwin's property is zoned residential, as is the Plaintiffs' property.
47. The hosting of events and carrying on of business or commercial activities is a
direct violation of the Little Rock zoning restrictions.
48. Plaintiffs respectfully request and are entitled to an immediate, temporary and
permanent injunction that would enjoin Defendants from hosting events at the property
and from otherwise violating the residential zoning restrictions.
Count III — Nuisance and Quiet Enjoyment of Property
7
49. The hosting of events at the Goodwin's property constitutes a nuisance and
directly impedes and prevents Plaintiffs' quiet enjoyment of their property. The loud
music, noise, light pollution, dangerous conditions created by allowing attendees to drink
and drive, increased traffic from commercial trucks and attendees and annoyance of
commercial delivery drivers and EMS and Fire Trucks showing up at Plaintiffs' and other
neighbors' properties late at night and early in the morning all create a nuisance and
disturb the quiet and peaceful enjoyment of Plaintiff s property.
50. The Defendants hosted an event just last Friday night. Based upon information
and belief, the Defendants are planning to host another event on October 26, 2024.
51. This event will exponentially increase the nuisance impact on Plaintiffs and the
surrounding neighbors. Defendants have not sought approval from Plaintiffs, and the
Plaintiff s knowledge, Defendants have not sought approval from the City of Little Rock
or any other authority to host this event despite such an event being in violation of both
the current zoning restrictions and the restrictive covenants.
52. Plaintiffs and the surrounding neighbors will sustain irreparable harm if
Defendants are permitted to continue to operate as an event center.
53. Plaintiffs are entitled to and hereby seek an immediate, temporary and permanent
injunction that would enjoin Defendants from operating an event center, hosting events
and operating a business or commercial enterprise on the property.
54. To the extent permissible under Arkansas law and the restrictive covenants,
Plaintiffs seek an award of attorney's fees and costs expended in pursuing this action.
M.
WHEREFORE, Plaintiffs move and pray for immediate, temporary and permanent
injunctive relief as forth in Plaintiffs' Complaint; for court costs and attorney's fees; for
the right to amend and plead further; and for all other just and proper relief to which they
are entitled.
RESPECTFULLY SUBMITTED by:
Isl Danny F- Crabtree
Danny R Crabtree (AR Bar No. 2004006)
Attorney for Plaintiffs
10201 W Markham, STE 328
Little Rock, AR 72205
501-372-0080
danny@crabtreelawar.com
VERIFICATION
I hereby state on oath and affirm the forgoing is accurate to the best of my knowledge
information and belief. lei,
,
Bo5by Wx ` on
STATE OF j 1lr
COUNTY OF \ ti
On this day personally appeared before the undersigned, a Notary Public within
and for the County and State aforesaid, duly qualified, commissioned and acting, that
Bobby Wilkerson appeared to me well known, and stated that he had executed the
foregoing for the purposes therein mentioned and set forth.
WITNESS my hand and official seal on thrG;1UU,-,J
1dof October 2024.
MY COMMISSION EXPIRES: CV'
NOTARY PUBLIC
CACYN COOK
Notary Public -Arkansas
Faulkner County
My Commission Expires 01-30-2034
Commission # 00000338
E
■ EAR.Cx' iCA i. iOj.iT
I hereby state on oath and affirm the forgoing is accurate tothe best of my knowledge
infoz-rnarion and belief.
Tom Burnett �S
STATE OF r-W)A0.v15aS
COUNTY
On this day personally appeared before the undersigned, a Notary Public within
and for the County and State aforesaid, duly qualified, commissioned and acting, that
Tom Burnett appeared to me well known, and stated that he had executed the foregoing
for the purposes therein mentioned and set forth.
WITNESS my hand and official seal on thip� day of October 2024.
MY COMMISSION EXPIRES. (51�
CADY{d COOK NOTARY P 1C
Notary Public -Arkansas
Faulkner County
[My
Commission Expires 01-30-2034
Commission # 00000338
VEIMICATION
I hereby state on oath and affirm the forgoing is accurate to the best of my knowledge
information and relief.
' Iennife ume
STATE OF PV-V-MSaS
COUNTY OF-��, .j
On this day personally appeared before the undersigned, a Notary Public within
and for the County and State aforesaid, duly qualified., commissionedwand acting, that
Jennifer Burnett appeared to me well. know, and -stated that she had executed the
foregoing for the purposes therein mentioned .and set forth -
WITNESS my hand and official seal. on this 9 "'° day of October 2024.
MY CON MSSION EXPIRES:
NOTARY PUBLIC
CADYN COOK
Notary public -Arkansas
Faulkner County
j My C.arnmission Expires 01-30-2034
T: Commission # 00040338
10
I1;iMCATION
I hereby state on oath and affirm the forgoing is accurate to the b my knowledge
information and belief.
de
STATE OF Sae7
COUNTY OF
On this day personally appeared before the undersigned, a Notary Public within
and for the County and State aforesaid, duly qualified, commissioned and acting, that
Brent Medders appeared to me well known, and stated that he had executed the foregoing
for the purposes therein mentioned and set: forth. ,,//
WITNESS my band and official seal on this ��d day of October 2024.
MY CMMSSION EXPIRES: Ql-11-' ' N- - '5� ��QIIA I---
OT Y PUBLIG
SAMANTHA LEEGH PUGH
Notary Public -Arkansas
Puiaski County
My Commission Expires 01-12-20.33
Commission f 12722127
11
VERIFICATION
I hereby state on oath and affirm the forgoing is accurate to the best of my knowledge
information and belief.��
4'�ower
STATE OF } 4Vk.
COUNTY OF TLA
On this day personally appeared before the undersigned, a Notary Public within
and for the County and State aforesaid, duly qualified, commissioned and acting, that
Jack Bower appeared to me well known, and stated that he had executed the foregoing for
the purposes therein mentioned and set forth.
WITNESS my hand and official seal on this ny of October 2024
Nty..CONIMISSION EXPIRES:
NO ARY PUBL
CAOYM COOK
Notary Public -Arkansas
Faulkner County
my Comrriission Expires 01-30 22034
Commission # 0000033a
VERIFICATION
I hereby state on oath and affirm the forgoing is accurate to the best of my knowledge
information and belief.
tney ower
STATE OF �lS�
COUNTY OF
On this day personally appeared before the undersigned, a Notary Public within
and for the County and State aforesaid, duly qualified, commissioned and acting, that
Whitney Bower appeared to me well known, and stated that she had executed the
foregoing for the purposes therein mentioned and set (forth.
WITNESS my hand and official seal on this %AV'do y of October 2024.
NIY CONIlVIISSION EXPIRES:
C
NOTARY PUBLIC
CADYN COOK
Notary Public -Arkansas
Faulkner County
My Comneission Expires 01-30-20- -34
Commission # 00000338
12
VERIFICATION
I hereby state on oath and affirm the forgoing is accurate to t e best of my knowledge
ni infonation and belief. 'p
2
Cha Spann
STATE OFPYY wA-11 )
COUNTY OFi3,
On this day personally appeared before the undersigned, a Notary Public within
and for the County and State aforesaid, duly qualified, commissioned and acting, that
Michael Spann appeared to me well known, and stated that he had executed the foregoing
for the purposes therein mentioned and set forth.
WITNESS my hand and official seal on this 9�rday of October 2024.
MY
O C--
CADYN COOK NOTARYP IC
Notary Public-
Arkansas
Faulkner County
My Commission Expires 01-30-2034
Commission # 00000338
VERIFICATION
I hereby state on oath and affum the forgoing is accurate to the best of my knowledge
information and belief. f
.dill
0-IS
STATE OF PO'
COUNTY OF
On this day personally appeared before the undersigned, a Notary Public within
and for the County and State aforesaid, duly qualified, commissioned and acting, that
Kristy Spann appeared to me well known, and stated that she had executed the foregoing
for the purposes therein mentioned and set forth.
WITNESS my hand and official seal on this `day of October 2024.
MY COMMISSION EXPIRES:
NOTARY P WC
CADYN COOK
Notary Pubic -Arkansas
11 Faulkner County
My Commission Expires 01-30-2034 l
Commission # 00000338 !
13
10/09/2024 14:52 15019551194
PAGE 15/15
VF,RXFICATION
i hereby state on oath and affirm the forgoing is accurate to
information and belie£
STATE OF r YV4,;54S
COUNrrY oli L.IAs fU'
the best ox my knowledge
AEithrris
On this day personally appeared, before the undersigned, a Notary- Public, within
and for the County and State aforesaid, duly qualified. commissioned au4 acting, that
Keith Morris appeared to me well known, and sMted that he had executed the foregoing
for the purposes therein mentioned and set forth.
WITNESS my hand and official seal on:thisjday of October 20124.
MY CN�'
I]BLI
. �rlvi '-ATON
i hereby 5L'%aj lio 4 ` nd affirm the forgoing is accurate to the best of my kmowledge
inforxuation and belief,
Bish.awu l�arris
STATE OF
COUNTY OF LC s k -
On this day personally appeared before the undersigned, a Notary Public vcrithi
and for the County anal State aforesaid, duly qualified, Comm issioned and acting, that
Bishawn. Morris appeared to mw well known, and stated that she had executed the
foregoing for the purposes therein mentioned and set fortb.
wiTNESS my band and offacial seat on this day of, October 2024.
1v1Y COMMSSION =]RES:
`\ ��h�lllftlllflf� r��r r
? Y stunt
PUB
rrrfr��CON,
14
EXHIBIT
2001085269
18/31/201 05;52:49 AN
Filed & Retorded in
Official Reeards of
CAROLYN STALEY
PULASKI COUNTY
CIRCUIT/COM Y CLERK
Fees S56.00
EXHIBIT "C" TO THE LAND SALE AGREEMENT
DECLARATION OF COVENANTS, RESTRICTIONS,
EASEWNTS, CHARGES AND LIENS
FOR GOODWIN ESTATES
� 00 092
This DECLARATION, COVENANTS, RESTRICTIONS, EASEMENTS,
CHANGES AND LIENS FOR GOODWIN ESTATES (this "Declaration") made
this 16th day of October , 2001, by Cary Goodwin and Andrea Goodwin, husband and wire
(hereinafter referred to as the "Goodwin! " ).
RECITALS:
Goodwins are the owners of the fallowing lands (the "Property"), which is
approximately 99 3)72 acres in size and all of which said Property lies in the County of
Pulaski, State of Arkansas, to wit:
That land described on Exhibit "A affixed hereto and by this
reference expressly made a part hereof,
and it is deemed desirable that the Property be divided into building lots of greater than. 5
acres each by the Goodwins, and that the Property be held, owned and conveyed subject to
the protective covenants herein contained Furthermore, The Property includes the following
tract of land (the "Mountain. Top Lot"), which is approximately 13.5 acres in size and which
the Goodwins intend to sell to Jack Hartsell and Paula A_ Hartsell, husband and wife, and
Claude M. Ballard and Mary B. Ballard ("Purchasers"):
That land described on Exhibit "B", affixed hereto and by this
reference expressly made a part hereof,
NOW THEREFORE, the Goodwins, for and in consideration of the benefits to accrue
to them, which benefits they acknowledge to be of value, declare that any interest in the
Properly shall be held, owned and conveyed subject to and in conformity with the following
covenants which, subject to being amended or cancelled a&,h ,vi ded, with the
h 12 which shall be perpetual, to-
exceptton of paragraph p rP
DECLARATION / PAGE 1
n
6
�r+:as��s►s� o
ZOOO93
1. SCOPE OF APPLICA-00N.
Goodwins are the owners of Property (also referred to herein as the "Addition").
GOodwim intend that the Addition be developed into a controlled gated residential
commun'ty of estate -size tracts (the "Lots", or a "Lot"), with each Lot having an area of
more than 5 acres, to ensure the protection and privacy of homeowners situated within. the
Addition. The residences will be single-family residences of the highest class of
workmanship and the best quality of materials. Any structures built on, and all activities
occuaring on, the Lots are to be in accordance with the general plart to develop this property
for the highest class of residential occupancy. However, Goodwins retain the absolute right
to determine the size, shape and boundaries of any Lot within the Addition, so long as such
th
Lot includes more an 5 acres of land. Goodwins shall fix the boundaries of Lots within the
Addition by the execution and filing for recordation in the office of the Circuit Clerk and ex
ofificio Recorder of Pulaski County, Arkansas of a written instrurtimt (including a deed)
expressly stating intention so to fix the boundaries of a Lot so described in this instrument.
The Mountain Top Lot is a Lot for purposes of this Declaration, subject to the provisions of
Section 2 hereof. A Lot shall be deemed, for purposes of this instrument, to include more
than 5 acres if the Goodwins have obtained a description of the Lot from a land surveyor
who states that such Lot includes more than 5 acres, even if such description states the
acreage is "approximate" or `more or less" than a number of acres which is more than 5
acres. The Goodwins hereby retains the right to reserve all mineral rights in the Addition at
the time of any conveyance of land or Lot in the Addition.
2. LAND USE AND is M ING TYPES.
Each Lot shall be used for single-family, residential homes only and be more than 5
acres in area_ No Lot may be subdivided into more than one lot, except as otherwise
in
provided herein; and provided that Goodwmay subdivide the Property as set forth in
Section i hereof. No structure shall be erected on any Lot nearer than fly (50) feet from
any property line and seventy-five (75) feet from front property line or any other access or
easement point. Front property Be refers to the property line adjacent to the Common.
Easement Property_
Porches, steps, chimneys, window boxes and other portions of a permitted stricture
shall not project beyond the minimum setback line, but, except as herein limited, eaves and
cornices may overhang the building setback lines_
DECLARATION f PAGE-2-
200094
In the event that any person who owns a Lot in the Addition (a "Lot Owner")
purchases two (2) or more contiguous lots, then the Lot Owner may build within those Lots
as if it were one Lot, subject to the other requirements herein.
No business or commercial use shall be carried on or permitted in any structure or in
any portion of this addition. This includes, but is not limited to, the leasing of any portion
of any structure on the Property. In addition, no noxious or offensive trade or activity shall
be carried on upon any Lot; nor shall anything be done thereon which may be or become a
nuisance to the neighborhood
Notwithstanding any other provision ofthis Declaration, the Purchasers and their heirs
and assigns shall have the right to divide the Mountain Top Lot into not more that two lots,
neither of which consists of less than five acres, provided that the dividing line between the
two lots consists of a straight line.
A IR Qr '%kII $TfUPlI�
The size, design, location and site development of any dwelling, permitted accessory
building, wall, fence, or any other structure built in the Addition shall be subject to the prior
approval of the Goodwin as provided in paragraph 4 herein~
No Lot Owner shall build and the Goodwins shall not approve any plans which
provide for construction of residences on a Lot or Lots in this Addition having less than four
thousand five hundred (4,500) square feet of heated and cooled liveable floor space,
exclusive of garages, measured by the outside wall dimensions. All dwellings placed upon
any Lots shall be of new construction and shall be of the highest class workmanship and best
quality materials. No building shall be erected, altered, placed or permitted to remain on any
Lot other than one (1) detached single-family dwelling not to exceed two stories in height.
Each dwelling on any Lot must have a private garage for the storage of not less than two
automobiles. Garages shall have a minimum of 400 square feet with minimum outside
dimensions of 20 x 20 feet. All garages shall be finished inside and shall be fully enclosed
with garage doors..All driveways in the Addition shall consist of a hard surface acceptable
to the Goodwins:
No existing, erected building or structure of any sort may be moved onto or placed
on any of the Lots.
No temporary or permanent structures shall be utilized for living quarters on any Lot,
including, but not limited to: trailers, mobile homes, manufactured housing, tents, shacks,
recreational vehicles, or other outbuildings.
DECLARATION / PAGE 3
20,00095
No accessory buildings on any Lot shall be built in front (i.e. facing the Common
Easement Property) of the rear building line of the main structure. The interior area of any
mum dwelling sizes -
accessory buildings will not he included in the determination with the mastructure and of
All accessory buildings will be aesthetically compatible
permanent type construction consistent with the Scope of Application in Section 1 hereof
There is to be no more than one (1) accessory building per Lot. No accessory biding will
the Lo
be permitted or constricted nearer than fifty (5tl ) feet to any property line of t or
between the building line of the principal dwelling and any of the Common Easement
Property as described in Section 1.2 hereof
All fences are to be constructed of wood, brick, or natural stone. Barbed wire, chain
link or any other fencing of this nature is forbidden- It is the intention of this covenantattiAny fence
require permitted fencing to be of a decorative to reaand ofpeamaned not solely nttypeconstruction.
skull be aesthetically compatible with the main
Retaining walls, ornamental fences composed of brick, wood or natural stone
constriction may be permitted on a Lot, provided, however, no fences shall be co truc �£
ted
between the dwelling and the Common Easement Property or closer than fifty }
fee
the Common Easement Property.
4. AgCHt"rEC'I`YiRAL CONTROL.
No residence, permitted accessory building, fence, 'wall or other structure shall be
constructed, created or maintained upon any lot in the addition, nor shall any modification,
alteration or change be made in the exterior of any existing residence or permitted accessory
building until the construction, grading and drainage and landscape plans and specifications
showing the nature, size, shape, dimensions, materials and location of the same shall have
been submitted to and approved, m writing, by Goodwins, or Goodwins have waived their
right in the manner hereinafter provided. Approval of plans for construction of principal
residences and permitted accessory buildings ��e exterionot be of suchbly p proposedld pricy the
Goodwins based upon the style of design o
cipal
residences as long as the same are designed, in whatever style, in accordance with the highest
standards of ambitectural design. The Goodwins intend to keep the image of the Addition
as afamily neighborhood of compatible architectural styles, materials and colors which blend
Harmoniously with the natural setting of the Addition. Because of the terrain of the Addition,
the Goodwin recognize that special situations may arise which will require necessary
deviation from dwelling locatiouregiiirements, but such deviation may only occur upon prior
written approval of the Goodwins. The Goodwins skull incur no liability by reason of its
refusal to approve any plans or specifications submitted hereunder.
tDECLARAMN / PAGE 4
W0096
5. ARCHITECTURAL APPROVAL PROCEDURE.
(a) Procedure for Obtaining.Approval from The Goodwin.
Any Lot Owner seeking to obtain the required approval of any plans for constriction,
modification or alteration or improvements on his, her or its Lot shall prepare detailed
architectural plans for the project and submit two (2) copies of the plans to the Goodwins.
K with thirty (30) days from the date of delivery of such plans to the Goodwins, the owner
has not received written notification of deficiencies in the proposal for such construction or
alteration or improvements, the Lot Owner may proceedwith suchconstruction or alterations
asthough afi mativeapproval had been received from the Goodwins. A written receipt from
the Goodwin shall be prima facie evidence of the delivery of such plans and the date
thereof.
(b) Procedure for Notification of Deficiencies.
Notice of any deficiencies shall be given to the Lot Owner at the address for the Lot
Owner indicated in the city telephone directory or as otherwise indicated by the Lot Owner,
in writing, by certified mail with reWm receipt requested_ If deficiencies are noted in the
proposed plans and called to the Lot Dwimer's attention within the thirty (30) day period
following delivery, the Lot Owner shall not proceed with any such construction or alteration
until such deficiencies have been corrected to the satisfaction of the Goodwins. After the
deficiencies are corrected, the Lot Owner must modify his or her plans and resubmit them
to the Goodwin for approval.
(c) Procedure for Enforcement of Restrictions.
Any Lot Owner may report a violation of any of these restrictions to the Goodwin.
A cha rge often dollars per day will be charged by the Goodwin to any Lot Owner who does
not adhere to these restrictions. The charge begins to accrue three (3) days after the
Goodwin notifies the Lot Owner, by certified mail, that the he or she is in default and has
three (3) days to correct the default. Mthe Lot Owner does not cease the violation after the
three (3) day period, the Goodwin shall have frill power to enforce all of the restrictive
covenants of this Declaration by any legal means as fully as though they were the Lot
Owners of property in the Addition and whether or not they are actually owners of property
in the Addition. Such enforcement shallbe by any procedure at law or inequity against any
person or persons violating or attempting to violate any of the restrictions for any available
remedy, including, but not limited to, specific performance, injunctive relief, or monetary
damages.
DECLARATION / PAGE 5
060009'7
Any costs of enforcing these restrictive covenants, including reasonable attorneys
fees, shall be paid by the violating Lot Owner. In addition, the Goodwins may assess a
reasonable fee to all Lot Owners for the purpose of obtaining legal counsel, but only if it
become necessary to seek the advice of as attorney to enforce these restrictions.
6. GENERAkL RESTRICTIONS.
No signs, billboards, posters or advertising devices shall be permitted upon any ofthe
Lots in this Addition except that the oRmer of each lot may place house numbers and the Lot
Owner's name upon his or her mail box or dwelling; however, each letter thereof shall be no
more than 6 inches in height and 6 inches in width; and Lot Owners may place a sign, not
more than 4 square feet in size advertising the property for sale should it be offered for sale
by the Lot Owners.
No animals, livestock or poultry of any kind shall be raised, bred or kept on any Lot;
except for horses, not to exceed two homes per Lot, which may be kept for domestic
purposes only. Other household animals, including dogs and cats, may be kept as pets,
provided that they are not kept, bred or maintained for commercial purposes or kept in such
numbers ar manner as to constitute a nuisance, danger, or health hazard or so as to interfere
with the peaceful enjoyment by other Lot Owners of their Lots.
No trash}, ashes or other refuse may be thrown or dumped on any of the Lots. Further,
during construction, no trash may be burned on any Lot. All waste must be removed from
the Lot by use of a licensed waste removal company.
No mail carts, dune buggies, golf carts, .mobile homes, commercial vehicles, travel
trailers, campers, boats, motors or trailers shall be kept on the Lot or in the street adjaw ut
to any Lot except that such items may be stored or parked inside an enclosed garage or
similar enclosure so screened with fencing or plant material as not to be visible from the
street.
Grass, weeds -and vegetation shall be kept mowed and cleared at regular intervals on
each Lot by the Lot Owner thereof so as to maintain the same in a neat and attractive
manner. No debris shall be allowed to accumulate upon any Lot. Dead trees, shrubs, vines
and plants shall be promptly removed from each Lot. The Goodwins shall have the right;
privilege and option to cause any unkept Lots to be mowed and to remove dead trees, plants
or other vegetation and debris from such Lot if after ten days` notice in writing, from the
Good wins to the Lot Owner, the Lot Owner has failed or neglected to do so, and the
Goodwin shall be entitled to a lien on such Lot for the cost of such work
DECLAR.AUON f PAGE 6
200098
No inoperable or unlicensed vehicles shall be allowed to remain on any Lots.
Hunting and discharging of firearms in the Addition is prohibited.
No satellite dishes or similar equipment with a radius in excess of 18 inches may be
located on any Lot:
7. DMSION OF LOTS.
No Lot maybe subdivided into more than one lot.
S. DEF1NMON OF "PRINCIPAL DWELLING" AND OTHER TERMS.
The term "principal dwelling," "resident" or "principal residence" or "dwelling" as
used in these restrictive covenants shall refer to a residence meeting the requirements hereof
and approved by the Committee for construction in the Addition.
9, EASEMENT AND RIGHT OF --WAIF GRANT.
Goodwins hereby grant, bargain, sell and convey unto each Lot Owner and to their
heirs and assigns forever, a perpetual non-exclusive street easement and right-of-way on,
over and across the following described land (the "Common Easement Property") lying and
being situated in the County of Pulaski, State of Arkansas, and described on Exhibit "C",
affixed hereto and by this reference made a part hereof. Goodwin have constructed or have
contracted with Purchaser to construct a blacktopped and gravel roadway, gated entrance and
landscaping across and over the Common Easement Property, which shall be accessible for
ingress and egress by each Lot Owner, his immediate family living with said Lot Owner and
his invitees, to the Property, which rights shall run with the land. Neither the Common
Easement Property nor any lakes or ponds built in the Addition shall be open to the public
and the Goodwin may control access to the Common Easement Property by use of lochs and
keyed entry to the Addition. Goodwin shall have the exclusive right to determine the
amount and natum of any maintenance and improvements in or on the Common Easement
Property and shall have the exclusive right to construct any improvements in or on the
Common Easement Property.
Each Lot Owner shall reimburse the Goodwins for their pro -rasa portion (the "Pro-
Rata Portion") of the costs of maintenance of and future improvement for the entrance gate,
fences, road, landscaping and utility usage on or for the Common Easement Property,
provided, however, that the total costs shall not exceed the sum. of $10,000.00 each calender
year unless such expenditures in excess of $10,000.00 have been approved by prior written
DECLARATION / PAGE 7
200099
consent of a majority of the Lot Owners obligated to reimburse such costs and provided,
further, however, that the Purchasers, personally and not their respective heirs and
assigns, shall not be obligated to reimburse any costs unless all the Purchasers shall first
have approved such expenditures by a prior written consent. The Pro-Rata Portion shall
be a percentage determined by dividing one by the number of single family residential houses
constructed in the Addition (which on the Effective Date consists only of the single-family
residential house ofthe Goodwin). Once a single-family house has been constructed on the
Mountain Top Lot, the Pro -Rats Portion shall be 50% until other houses are constructed in.
the Addition.
The obligations of Lot Owners to reimburse costs for maintenance and improvements
pursuant to this instrument shall constitute alien against the portion of the Property owned
by such Lot Owner who owes same until the obligations are paid in full. The Goodwins,
their designees, successors, heirs and assigns, shall respectively have the right, power and
authority to enforce the collection of any such charges, if not paid on demand, by proceeding
in the Chancery Court of Pulaski County, Arkansas, the same as other liens are enforced on
lands located in said county and said liens shall cover and include all costs incurred in
enforcing same, including a reasonable attorney's fee.
10. PERSONS SOUND BY THESE COVENANTS.
The Goodwins and all Lot Owners of Lots in the Addition shall be deemed to
have agreed and covenanted with the Lot Owners of all other Lots in this Addition and with
its or their heirs, successors and assigns to conform to and observe the restrictions, covenants
and stipulations contained herein for a period of 20 years from the data these covenants are
recorded, and these covenants shall thereafter automatically extend in effect for successive
periods of 10 years unless prior to the end of the original term or any successive term ofthe
application hereof the then Lot Owners owning a majority of the land area of Lots in the
Addition agree to the amendment or removal of these covenants in whole or in part. These
covenants may be amended at any time by the then Lot Owners of Lots owning a majority
of the land area of Lots in the Addition. No changes in these covenants in the manner herein
set forth shall be valid unless the same shall be placed of record in the office of the Recorder
of Pulaslri County, Arkansas, duly executed and acknowledged by the requisite number of
Lot Owners.
11. RIGHT TO ENFORCE.
The covenants, agreements and restrictions herein set forth shall run with the title to
the Lots in this Addition and bind the present owners, their heirs, successors and assigns,
future owners and their heirs, successors and assigns; and all parties claiming by, through
DECLARATION / PAGE 8
200100
or under them shall be taken to hold, agree and covenant with the Lot Owners of other Lots
in the Addition, their heirs, successors and assigns. as to the covenants and agreements
herein set forth and contained. None of such covenants and agreements shall be personally
binding on any person, persons, or corporations except with respect to breaches committed
during its, his or their holding of title to Lots in the Addition. Any Lot Owner shalt have the
right to sue for and obtain an injunction, prohibitive or mandatory, to prevent the breach of
or to enforce the observance of any of the covenants, agreements or restriction contained
herein together with any other rights to which they might otherwise be entitled under the
laws of the State of Arkansas. The invalidation of any one of these covenants, restrictions
or agreements herein contained by the order of a court of competent jurisdiction shall in no
way affect any of the other provisions hereof which will remain in firll force and effect.
12. CflNSTRUC ICON AND UTMM S. Any dwelling, constructed on any Lot
must be completed within one year from the date that construction is commenced. No
building material of any kind or character shall be placed or stored upon any Lot in the
Addition until the Lot Owner is ready to commence construction of the improvements
requiring such materials. Building materials shall never be placed or stored in any street.
Each Lot Owner must provide adequate and proper sewer facilities and water supply
system for said Lot, in conformity with the then current regulations of the Arkansas State
Health Department. Exposed overhead wires and cable for utility services are prohibited in
this Addition. All utilities must be installed underground and be in compliance with
appropriate utility owners and agencies having jurisdiction over the Addition. Where streets
are cut for utility crossings or any other. damage caused by a Lot Owner, his agents or
contractors, repairs must be made by the Lot Owner causing such damage within a
reasonable time and such streets must be repaired to a condition comparable to the conditions
of such streets prior to such damage and acceptable to the Goodwin.
B. ANNEXATION OF ADDMONAL LANDS TO ADDITION.
The Goodvam shall have the right, from tune to time, to annex additional lands to the
Addition, and thereby subject the same to the restrictions and covenants applicable to the
lands in the Addition as provided herein by the execution and filing for recordation in the
office of the Circuit Clerk and ex officio Recorder of Pulaski Comaty, Arkansas of an
instrument expressly stating intentions so to annex and describing such additional lands to
be so annexed and the covenants and restrictions applicable thereto.
DEC7 ARA ON / PAGE 9
�00101
14. DURATION OF COVENANTS- AMENDMENT OF DECLARATION,
This Declaration shall run with the land and shall be binding on all parties and all
Persons claiming under them for a period twenty (20) years from the date this Declaration
is recorded with the Pulaski County Circuit Clerk and Recorder's Office. After this period,
this Declaration shall be automatically extended for successive periods of ten (10) years each
unless and until terminated as provided in this paragraph 17. These covenants can be
amended or terminated by the recording of an instrument signed by a majority ofLot Owners
(with each Lot droner or Goodwin awning more than one Lot being treated as a separate
Lot Owner for each Lot owned by that Lot Owner or Goodwin for purposes of determining
a majority) of the Lots owned by the Lot Owners and Goodwins in the Addition in the office
of the Pulaski County Circuit Clerk and Recorder's Office- Provided, however, none of the
restrictive covenants herein contained may be modified, terminated, amended or canceled
prior to the end of the initial twenty (20) year term, without the prior written consent of the
Goodwin, as long as Goodwins owns any part of the Addition.
I5. ASSIGNMENT OF GOODWINS' RIGHTS AND DUTIES.
Any and all rights, powers and reservations of the Goodwin herein contained may
be assigned in good faith by the Goodwins to any responsible person, corporation or
association or committee who has a legitimate interest in the subject matter hereof which
will assume any or all of the duties of Goodwin hereunder, and upon any such person,
corporation or association's evidencing its consent in writing to accept such assignment, said
assignee shall, to the extent of such assignments assume Goodwins' duties hereunder, have
the same rights and powers and be subject to the same obligations and duties as are given to
and assumed by the Goodwins herein- Upon such assignment, and to the extent thereof; the
Goodwins shall be relieved from all liabilities, obligations and duties hereunder. The term
"Goodwin" as used herein, includes all such assignees and their heirs, successors and
assigns.
IN WITNESS WHEREOF, the Goodwin have hereunto set its hand and seal this
Isth day of . Uct)her 2001. _
Gary Ga� � w t
-- ���
An ea Go dwihn
DECLARMON / PACE 10
STATE OF ARKANSAS
COUNTY OF PULASKI
ACKNOWLEDGEMENT
200102
On this 16th day of October , 2001, before me, a Notary Public, duly
commissioned, qualifced and acun& within andfor said County and State, appeared in person
the within named Geary Goodwin and Andrea Goodwin, to me personally well known, who
stated that they executed and delivered said foregoing instrument for the consideration, uses
and purposes therein mentioned and set forth..
IN WITNESS WBEREOF, I hereunto set my and official se
My commission expires: 8/25/2010
4 •r.-�rinc+ttrfce_ 611$-Z6R.CahiLiitrf3S���'4•^Y" �1sti� � � � �i� ej r �/rr ,
�1W2�rc_._...___ lBOElisaada+i��
T
NOTARY I=
PUBLIC
c olj�4 . ``
DF,CLARA,noN / PAGE 11
VITA 200103
DESCRIPTION OF THE
"PROPERTY"
Attached
E6q�
C
200104
r.� IT "A." TO M DECLARA=W OF C0NVM Ann
'bract I: Part of the Norrhz=Y,, Monrhwesr7114 and the Northwest %, Northeast % of Section
25, Township 2 Noah, .Range 15 West, PuLmd County, A2tansas being more
particularly dewnbed as follows:
Bee uzn_ng at the Southwest corner of the Northeast Y, of the Northwest ii; thence
North 00 `02' 04" West alang the West line of the Norrheast 4. of the Northwest
a distance of 1387.28 feet to dL- Norhwest comer of t} e North= % of the Northwest
1; dience So=h 89 "53' 49" East along the North line of ,Section 25 a distance of
2624.91 feet to the Northe= corner of the Northwest Yl of the Northeast Y4; thence
South 01 ° 00' 48" East along the East Line of Northwest V4 of the Northeast % a
distance of 1334. i3 feet to the Southeast corner of the Northwest ii of the Northeast
46; thence South 88 ° 57' 40" West a distance of 2648.11 feet to the POLVT OF
BE.GPffiWG comdaing 82.37 acres, more or Less. -
Tract 2_ 'Fart of the Southwest !S of the Northeast 414 of Secnon 25, Township 2 North, Range
15 West; Pulasla County, Anlcnnsas being more particularly described as follows: .
Starring at the Southwest corner of the Northeast Y4 of the Northwest '/a of Seaion 25;
thence Norh 88 " 5T 40" East along the South line of said Northeast Y4 of the
Northwest i4 a distance of 1539.11 feet to the PONY OF BEGWjVItVG; thence
coru'i=ing North 88 ° 57' 40 R East along the South Line of the Northwest :V% of the
Northeast V4 a distance of 1109. 00 fee: to te Northeast corner of Southwest Y of the
Northeast %; thence Soidi 00 ° 39' 33 " East along the East line of said Southwest '/a
of the Northeast * a dtsr we of 1335. 67 feet to the Southeast corner of the said
Southwest M of the Northeast �Vt; thence North 40 ° 31 ' 00" Mess 1730. 39 feet to the
PdN2' OF BEGP4VVG cor=&zing 17.002 acres, more or less.
CQPIlP12Q'CI�,�..�]�iYaIS'QlS, Zf� %
EDIT B 2U0105
DESCRIPTION OF THE
"MOUNTAIN TOP LOT"
Attached
;....n��� `.�y ���'��'4ti'�1�.�'�-`•
L1 �;_Tlli;.�;:w••.ti
�A
��ti*�y.o��......�.f i�'S�-..�
.axu. �. .., �,�; a �LrG'r' "._-;�"Z`�'
a1i�'.'xi+ .ic^.�y.'��.�ct�. �
. �'' �� ti���:� n—'� ti -' +:' +s"+•' _v.. �
-
---200106
CIS "351 M ME DH4MAIa TICV OF COVM -S
PW.;; of t7za jivr' est :1 of the LTur-&east ;/4 of Seczi25, :'a-t ;'ri-D ? iYCTth, ; range 15 Tast
8o=q :Hare 1 7; �r+ --ld 0 cescrti�ed cs
� G3J 7',�G az zhe - crrtlw= corner of said 1Vc�west X of trze Ncr�5u=- �e of Uecu t ?a; tzerNc2
w autr 00�5 r'' r r3' East abo�g the
N� d�z.e of .�w;d N�jcr ,5=esz ,, of t ae N oTthe� r a distc=g as
388.97 feet to a 'Poi7Zt iM t7te centorL�e of x 5 fdOU wi z gr=GL road; $;7,e7ica vio»rr sdiri
cormterz ze the fQi.cuxi^ag e'rt (1 } uses =zd distances (I) c ^2 -Vardk 66'08'63" West ¢
d-st=zoz of 9,L_81 feet; (2) fforsn. 8,'-,6'58'° Nest, a diztcnce of 41-16 feet; (3) t]ze ce work?
a c°Lr-;e to the ieJ GG tar uir,� rcrays of i 5.5a feet = arc �n�hc of �_Oo fees end a cn.crd wizi n.
bea:-s Sou-t7z d-�30'39- Test 30.72 fee&; (-4-) the -=a Saze�,& 5, *08'4.2' Eas't, a dista- ce of 7-94 fret;
(�} thence Sam SI'4s' 2' first Q disFrirzce of a4-86 feet" (5) ift-owe S�.Fa 37'09'29" 'ast a
on Or -
distance of 97-27 fser; a clMg m -urve to tke '7-'}h-t h='.g a radius of 8- 17 feet
aengtt of 51.44 feet curd a chard wi ic& bears Soz, i 1.2'24' d$' Fast 60,11 feet (7) ar z=e Sri
go,55'4,3- amass a diF-,=zce of 4.9.66 feet: (a) ih n.^2 Sauth. f2600'f7" Nrest, d dzsta=a Of 85.33
feet; (9) tixeywc aLong m curve to th-c righ;u 7=vsnj s rmdivs of 221-3.2 fuct Orr, ua'c �ryLFt of 2D6.u8
txrad cz ri xui-,zox 22C0ssc7�-56` 07 " sf
1e& eiorri yearew
a cLstunce of f17-36 f�; (11 ) tizerce S�r�ia 63,31'578- 77esza dzst=zce of 55.97 ,bet; s"nercca
,rOT-tia 18° f &' o6- x dti. ce of 3 p_ 12 feet; U e rasa N07 to .24' 10' 53" }Vest d of 139.50
fees: VZence X 48"53'3.2" West x di tm—we of .203.38 fees; ff ert:e Iro;� 6f'56'63' Fesfi 9,
dista=e of 206B4 f--et; thz=e 'farms 44'MR7" }lest, a o d e of .261.22 set; iz^lxtra ToTcr'.
44'58'27- TreVi; a distance of 100-00 feet; thzazef�a TaTth 00°06' 1 1 " i���ds�� a list cca of 1 _99 feet
-cc a pm= an thz ?Vora+. Line of said Norrkuess r� bf th-C YQVtnZCSt Ye SaM a S9a48'Sw7
o'rag said Norse Line, a see -Lce of ; 077.68 feet tO � POUN 0
lcsi �F B-8C k7i G cmcaaz?P-mg f3.�aci
dares, =are or Lew
�OU10'7
EXE BIT C
DESCRIPTION OF THE
"COMMON EASEMENT PROPERTY"
Attached
200108
TO THE DECLO-6,..ION OF COVE iL
=77-SMS SFr R?7,..2iiLETos
iree ?Vm�: c of
5,w ?vaa'� xeest ¢l
uGcsti 2Yc -sxs 5ezrac �rtara _ ^"-LmacN"iy de--"iZ26 = Ca. ws;
:ane ,�rrx. e= sari �vorhe �� �; ze ?v rn- -sue f la'
rc irae 1 �� �7 to tine@��-
:, .a 7sL•2"- O r' LL''LL' +�1'QiC Uazs Yd aj %IL2 OT .'�2 �i a GS't5"� Opa 0� 355• 41
:r2SC i%Z07L� 1 77i772 Of S a T = ? arr'L 6 459 eieZS G
7"'S7'� f 6' ^ xs� c �tisr:�zca of 22616 ' Bey: r
D?��Gr'N?�13VG,rtCa 5aua�c 5 Gam--ts '•o¢�5�' �IJa 5cxz3"C3 :9'
ems: v^as2 0 52D.98 fE :n Fes+ zap u�.s ce�rceT ^:rc2 cf -
rs: mx s cVrC27+E_ ¢s�-2 aJ 3 ; _3Z �cz Sin
of 570.31fees: ii- s �?'crdz '-o =5' rarer a dzst -tee of 207.13 j a gocrtz
o e I'{rBSL �7;LE c�tlm� 8
CyvaTftw=t Y of t?w e=e. Test ¢iQ7W said Ypst
rau a s aaoa at 5°.5� f ra rias FONT ❑F agcm omrc- oar ta4r n9 0.828 acres, mart or less
Andrea Goodwin
Jennifer Maune
3708 Garrison Road
Little Rock, AR 72223
August 11, 2024
Department of Planning and Development
723 West Markham Street
Little Rock, AR 72201
To whom it may concern,
We are requesting a zone change forwhat is currently known as Goodwin Manor, located at 3708 Garrison
Road, Little Rock, Arkansas 72223, to a Planned Commercial Development.
Goodwin Manor is a European style estate uniquely built using fieldstone from Hackett, Arkansas. The
extensive ironworkwas designed and installed by a Joe T. Robinson graduate, and the home's woodwork
was handcrafted by Arkansas artisans. The property is being soLd alongwith 24 acres and will remain a
family residence, but as a secondary use of the home, we envision adding components to create a working,
regenerative farm. Over time, we plan to add a vegetable garden, an omamentalflower garden, green
house, chicken coop, a barn to house farm equipment and livestock, and a studio kitchen.
Chef Jennifer Maune plans totake on the property and live in and maintain the home with herfamily, but
also utilize the property to grow crops, herbs, flowers, and livestockto develop products available for her
restaurant and potentially others, along with retail use. in addition, we'd Like to open the property up to
educational/agriculturalfield trips for public school kids, community and charity events, culinarythemed
events, along with educational garden and farm tours.
Access to the property is via a private road via an easementto Garrison Road and traffic is limited. The
hours of operation will be between 9 am and 10 pm, with limited evening events and in compliance with the
Pulaski County Noise Ordinance. We will ensure ADA standards are met for parking, access and restrooms,
and that no more than 200 guests are allowed at any occasion.
With Chef Jennifer Maune's success on the show MasterChef on FOX Network, and notoriety in Arkansas
and beyond, we are excited to envision this treasure of a property as a valuable source of educational
experiences, community enrichment, and positive representation of the city of Little Rock and state of
Arkansas.
We lookforwardtoworkingwith you auto implement a plan, thankyou for your consideration.
Best,
Ma
Andrea Goodwi Jennif une