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53. The City of Ramsey's claims and other legal contentions in their dismissed <br />actions were not warranted by existing law or by a nonfrivolous argument for the extension, <br />modification, or reversal of existing law or the establishment of new law. <br />54. The City of Ramsey's allegations and other factual contentions had no evidentiary <br />support and would have been known not to have evidentiary support if a proper investigation had <br />been concluded prior to filing the claims. But, the City of Ramsey conducted no proper <br />investigation before conducting its legal proceedings. <br />55. Kiefer has been damaged by City of Ramsey's dismissed legal proceedings. <br />COUNT II <br />TORT — TRESPASS <br />56. Paragraphs 1 through 55 are incorporated herein by reference. <br />57. Under the Minnesota Torts Claims Act, Minn. Stat. § 3.736, Minnesota has made <br />a limited waiver of sovereign immunity from tort claims including trespass. <br />58. Kiefer owned the real estate in Isanti County where the City of Ramsey dumped <br />the personal property from Kiefer's Isanti County property. <br />59. Plaintiff never invited the City of Ramsey or any of its agents or representatives <br />onto his property. <br />60. For the City of Ramsey through its agents to lawfully enter Kiefer's property, the <br />City of Ramsey has certain legal obligations to follow including providing proper and specific <br />notice to the property owners of both the City of Ramsey property and the Isanti County property <br />— Kiefer. <br />13 <br />