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80. The City of Ramsey violated notice legal requirements in conducting the <br />abatement. <br />81. Defendant Kurtis Ulrich, as City Administrator, failed to ensure the City of <br />Ramsey provided Kiefer timely specific notice prior to the October 2007 abatement. <br />82. The Defendants have failed and refuse to compensate Kiefer for property taken <br />from him. <br />83. Because of the failure of the Defendants to lawfully conduct its abatement, its <br />failure to pay compensation to Kiefer constitutes a violation of Minnesota Constitution, Art. I, <br />section 13. <br />84. Kiefer has been damaged due to the City of Ramsey's violation of Minnesota <br />Constitution, Art. I, section 13. <br />85. As part of its illegal entry, the Defendants and its agents took personal property in <br />an amount exceeding $50,000 in value as part of the abatement causing damages to Kiefer. <br />86. Kiefer also seeks all other relief this Court finds just, including attorney fees and <br />costs. <br />COUNT V <br />STATE CONSTITUTIONAL CLAIM — <br />UNREASONABLE SEIZURE OF PROPERTY <br />87. Paragraphs 1 through 86 are incorporated herein by reference. <br />88. Minnesota Constitution, Art. I, section 10 states: <br />Sec. 10. UNREASONABLE SEARCHES AND SEIZURES <br />PROHIBITED. The right of the people to be secure in their persons, <br />houses, papers, and effects against unreasonable searches and seizures <br />shall not be violated... <br />16 <br />