Date: May 15, 2025
Complaint Regarding Violation of Section 405.495, Unified Development Ordinance – Home Occupation Permit at 1147 Tower Park Dr., St. Charles, MO 63304
Fri, May 16, 11:59 AM - to planningandzoning
St. Charles County Planning and Zoning Division 201 N. Second St., Suite 412 St. Charles, MO 63301 Email: planningandzoning@sccmo.org
Subject: Complaint Regarding Violation of Section 405.495, Unified Development Ordinance – Home Occupation Permit at 1147 Tower Park Dr., St. Charles, MO 63304
Dear Planning and Zoning Division,
I am filing a formal complaint regarding an alleged violation of Section 405.495 of the St. Charles County Unified Development Ordinance (UDO) by Anthony R. Friedman, dba. The Friedman Law Firm LLC, at the residential address of 1147 Tower Park Dr., St. Charles, MO 63304. The violation concerns the operation of a law practice without applying for or obtaining a required Home Occupation Permit.
Facts of the Complaint:
- Business Address Listings:
- Anthony R. Friedman lists 6209 Mid Rivers Mall Dr., Ste. 204, St. Charles, MO 63304, as an address for The Friedman Law Firm LLC. This address is a post office box at a UPS Store in Dierbergs Markets - 94 Crossing. It lacks the infrastructure (e.g., office space, computers, filing systems, personnel) necessary to operate a law firm, suggesting it is not the primary place of business. [See Exhibits 1,]
- The residential address, 1147 Tower Park Dr., St. Charles, MO 63304, located in the Reserve at Lakeview Farms development, is also listed as an address for the law practice and listed as primary in legal and business filings. [See Exhibits 2, 3, 4,]
- Confirmation of No Home Occupation Permit:
- On April 29, 2025, I contacted the St. Charles County Planning and Zoning Division and spoke with “Mr.” Jared, who confirmed that, as of that date, no individual or entity at 1147 Tower Park Dr. had applied for or been issued a Home Occupation Permit. [See Exhibits 5, 6,]
- Evidence of Law Practice at Residential Address:
- Legal and court correspondence filed with the St. Charles County 11th Circuit Court Division, lists 1147 Tower Park Dr. as the address for The Friedman Law Firm LLC. This indicates that the law practice is being conducted from the residential property. [See Exhibits 7, 8, 9]
Basis for Complaint: Section 405.495 of the UDO requires a Home Occupation Permit for any business activity conducted in a residential dwelling unit, subject to specific conditions (e.g., no external evidence of the business, limited traffic, and compliance with zoning regulations). The evidence suggests that Mr. Friedman is operating a law practice from his residence without the requisite permit, constituting an ongoing violation of the UDO. This activity may impact the residential character of the Reserve at Lakeview Farms development and warrants investigation to ensure compliance.
Requested Action: I respectfully request that the Planning and Zoning Division:
- Investigate the alleged violation at 1147 Tower Park Dr. to confirm whether a law practice is being conducted without a Home Occupation Permit.
- Take appropriate enforcement actions, as outlined in Section 405.645 and Section 405.650 of the UDO, to remedy the violation, including issuing a written order to cease the unpermitted use or requiring compliance through a permit application.
- Keep me informed of the investigation’s progress, any enforcement actions taken, and the resolution of this matter.
Exhibits:
- Exhibit 1: [Description, Screenshot of The Friedman Law Firm LLC website listing 6209 Mid Rivers Mall Dr. as address and that of a UPS Store]
- Exhibit 2: [Description, Screenshot of Missouri Secretary of State business filing listing address at 1147 Tower Park Dr.]
- Exhibit 3: [Description, Screenshot of Missouri Secretary of State articles of organization listing address at 1147 Tower Park Dr.]
- Exhibit 4: [Description, Annual filing with the ARDC Supreme Court of the State of Illinois listing address at 1147 Tower Park Dr.]
- Exhibit 5: [Description, Screenshot of minutes kept with regard to planning and zoning home occupation permit inquiry with “Jared”]
- Exhibit 6: [Description, Word document of minutes kept with regard to planning and zoning home occupation permit inquiry with “Jared”]
- Exhibit 7: [Description, Screenshot of court filing with St. Charles County 11th circuit dated April 28, 2024 listing address as 1147 Tower Park Dr.]
- Exhibit 8: [Description, Screenshot of court filing with St. Charles County 11th circuit dated June 4, 2024 listing address as 1147 Tower Park Dr.]
- Exhibit 9: [Description, Screenshot of certified, registered mail with the St. Charles County 11th circuit listing address as 1147 Tower Park Dr.]
Please contact me at 314-580-1684 or email; gpckings@gmail.com for any additional information you may require. Furthermore, please keep me apprised as to the status and final disposition of the complaint and investigation. Thank you for your attention to this matter.
Respectfully submitted,
Albert B. Pepper