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61. The City of Ramsey violated its legal obligations thereby illegally entering the <br />City of Ramsey property and the Isanti County property because it failed to give adequate, <br />specific legal notice to Kiefer regarding the intended abatement. <br />62. As part of its illegal entry, the City of Ramsey, through its agents and <br />representative, took and destroyed personal property valued in an amount in excess of $50,000 as <br />part of the abatement. <br />63. As a direct result of the Defendants trespass upon Kiefer's property, the Plaintiffs <br />have been damaged in an amount exceeding $50,000. <br />64. Plaintiffs seek all other relief this Court finds just, including attorney fees and <br />costs. <br />COUNT III <br />TORT — CONVERSION OF PERSONAL PROPERTY <br />65. Paragraphs 1 through 64 are incorporated herein by reference. <br />66. Under the Minnesota Torts Claims Act, Minn. Stat. § 3.736, Minnesota has made <br />a limited waiver of sovereign immunity from tort claims including conversion. <br />67. Kiefer owned personal property which was taken by the City of Ramsey through <br />its agents during the October 2007 abatement and either destroyed the property or transported to <br />the Isanti County property. <br />68. Kiefer never asked nor requested the City of Ramsey or its agents to take their <br />personal property from the Kiefer property. <br />69. Before the City of Ramsey or its agents can lawfully take the personal property, <br />the City of Ramsey has certain legal obligations including providing proper notice to the <br />property owners. <br />14 <br />