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Attorneys a! Law <br /> <br />ROBERT A. ALSOP <br />BRUCE M. BATTERSON <br />RONALI) H. BATTY <br />STEPHEN J. BUBUL <br />,JOHN B, DEAN <br />DANIEL J. GREENSWE[G <br />DAVID J. KENNEDY <br />CIIARLES L. LEFEVERE <br />,JOHN M. LEFEvRE, JR. <br />ROBERT J. LINDALL <br />ROBERT C. LONG <br />JAMES M. STROMMEN <br /> <br />KENNEDY & GRAVEN <br /> CHARTERED <br /> <br />470 Pillsbury Center, Minneapolis, Minnesota 55402 <br /> (612) 337-9300 <br /> <br />Facsimile (612) 337-9310 <br /> <br />WRITER'S DIRECT DIAL <br />(612) 337-9215 <br /> <br />CORRINE H. THOMSON <br />JAMES J. THOMSON <br />LARRY M. WERTHEIM <br />BONNIE L. WILKINS <br />JOE Y. YANG <br /> <br />DAVID L. GRAVEN (1929-1991) <br /> <br /> OF COUNSEL <br />ROBERT C. CARLSON <br />ROBERT L. DAVIDSON <br />WELLINGTON H. LAW <br />CURTIS A. PEARSON <br />T. JAY SALMEN <br /> <br />February 14, i996 <br /> <br />Mr. Ryan Schroeder <br />City of Ramsey <br />15153 Nowthen Blvd <br />Ramsey, MN 55303 <br /> <br />RE: Starks and Fields v. MPRS; Allocation of Damages <br /> <br />Dear Mr. Schroeder: <br /> <br />I have received your letter of February 12, 1996 requesting a response to two questions. The <br />first question is whether it would not be more fair for the defendant cities to allocate damages <br />on the basis of size of police departments rather than population. <br /> <br />The formula which is described in the resolution was recommended by the MPRS executive <br />committee and approved by the MPRS board as a suggestion to the defendant cities. I was not <br />involved in the determination of that formula. I have advised the MPRS board and executive <br />committee that any position I would take on the allocation of damages would put me in a conflict <br />situation with all of the other defendant cities. I have indicated on a number of occasions that <br />it was my hope that the cities would be able to determine a mutually agreeable formula for <br />allocation of damages among themselves, so that litigation among the cities would not be <br />necessary. However, any change in the formula which is advantageous to one city is necessarily <br />disadvantageous to another. Therefore, because I am representing ail of the cities, I have been <br />unable to advise the MPRS on the formula for allocation for damages. For the same reason, I <br />cannot attempt to justify} agree with, or otherwise comment on your suggestion that another <br />formula might be more fair or reasonable. <br /> <br />With a copy of this response, I am forwarding your letter to Dan Donahue, the president of the <br />MPRS, for his consideration. <br /> <br />CLL100423 <br />MPllO-2 <br /> <br /> <br />