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70. The City of Ramsey failed to provide timely, specific notice upon Kiefer <br />regarding the abatement, the scope of abatement, and corrective measures that could be taken to <br />avoid abatement. <br />71. The City of Ramsey and its agents violated their respective legal duties thereby <br />illegally converting Kiefer's personal property. <br />72. As part of its illegal entry, the City of Ramsey and its agent converted personal <br />property in an amount of value exceeding $50,000 as part of the abatement. <br />73. As a direct result of the Defendants conversion of Kiefer's personal property, <br />Kiefer has been damaged in the amount exceeding $50,000. <br />74. Kiefer also seeks all other relief this Court finds just, including attorney fees and <br />costs. <br />COUNT IV <br />STATE CONSTITUTIONAL CLAIM — TAKING OF PROPERTY <br />WITHOUT COMPENSATION <br />75. Paragraphs 1 through 74 are incorporated herein by reference. <br />76. Minnesota Constitution, Art. I, section 13 states: <br />Sec. 13. PRIVATE PROPERTY FOR PUBLIC USE. Private property <br />shall not be taken, destroyed or damaged for public use without just <br />compensation therefore, first paid or secured. <br />77. The Plaintiffs owned the personal property which was taken by the City of <br />Ramsey and its agent during the October 2007 abatement. <br />78. The Plaintiffs' private property is protected by Minnesota Constitution, Art. I, <br />section 13. <br />79. The City of Ramsey and its agents took, destroyed and damaged Plaintiffs' <br />private property in the abatement. <br />15 <br />