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<br />That with the exception of the defendant, the City of Ramsey, hereinafter <br /> <br />"Ramsey", does not have another school within the city limits that serves kindergarten <br /> <br />pupils. Similarly, with the exception of defendant, Ramsey does not have another school <br />within the city limits that serves grades 6-12 pupils. <br />IV. <br /> <br />That based upon information and belief, defendant has since 2004 adopted an <br /> <br />erroneous enrollment policy in contravention of state charter school law contained in <br /> <br />M.S. 124.D. 10 subd. 9(3) that disadvantages all Ramsey resident kindergarten applicants <br /> <br /> <br />and grades 6-12 pupils making application for enrollment to defendant by failing to give <br /> <br /> <br />them the legislatively mandated enrollment preference. <br /> <br />V. <br /> <br />Further, defendant adopted and continues to adopt an erroneous "sibling" <br /> <br />preference list that disadvantages for enrollment Ramsey kindergarten applicants and <br /> <br />may disadvantage grades 6-12 applicants. <br /> <br />VI. <br /> <br />Plaintiff completed and mailed to defendant an application for kindergarten in the <br /> <br /> <br />fall of 2007 on behalf of his minor son. Defendant confirmed receipt of the application <br /> <br /> <br />and that plaintiff's minor son would not be given enrollment preference. <br /> <br /> <br />VII. <br /> <br /> <br />On or about January, 2008, plaintiff had discussions with defendant administrator <br /> <br />regarding what he believed to be a statutory enrollment preference for Ramsey resident <br /> <br />kindergarten pupils .i:rlaIcing application to defendant. Plaintiff was advised that there are <br /> <br />36 kindergarten slots available for the 2008-09- school year with approximately 150 total <br /> <br />-41- <br />