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89. The Plaintiffs owned the personal property which was taken by the City of <br />Ramsey and its agent during the October 2007 abatement. <br />90. The Plaintiffs' private property is protected by Minnesota Constitution, Art. I, <br />section 10. <br />91. The City of Ramsey and its agents unreasonably took, destroyed and damaged <br />Plaintiffs' private property in the abatement. <br />92. The City of Ramsey violated notice legal requirements in conducting the <br />abatement. <br />93. 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 />94. The Defendants have failed and refuse to compensate Kiefer for the damages <br />caused to him. <br />95. 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 10. <br />96. Kiefer has been damaged due to the City of Ramsey's violation of Minnesota <br />Constitution, Art. I, section 10. <br />97. 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 />98. Kiefer also seeks all other relief this Court finds just, including attomey fees and <br />costs. <br />17 <br />