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STATE OF MINNESOTA DISTRICT COURT <br />COUNTY OF ISANTI TENTH JUDICIAL DISTRICT <br />County of Isanti, Case Type: Civil <br />Plaintiff, Court File No. 30 -CV -11 -589 <br />v. <br />Keith Allen Kiefer, <br />Defendant and Third Party Plaintiff, <br />v. <br />City of Ramsey, and City Administrator Kurtis <br />Ulrich, in his official capacity and individually, <br />Third Party Defendants. <br />1 <br />ANSWER AND THIRD PARTY <br />COMPLAINT <br />Keith Allen Kiefer, Defendant and Third Party Plaintiff, files through Counsel this <br />pleading as his Answer and Third Party Complaint. <br />ANSWER <br />Keith Allen Kiefer for his answer to the Complaint alleges as follows: <br />1. Denies the allegations in paragraph 1 except as to Isanti County being a duly <br />authorized political subdivision of the State of Minnesota. <br />2. Admits the allegations in paragraph 2. <br />3. Denies the allegations in paragraph 3 only to the extent that the statutes <br />referenced authorize this action. <br />4. Denies the allegations in paragraph 4 because the City of Ramsey, not Defendant, <br />caused the purported violative conditions on the property. Specifically, on and about October <br />25, 2007, the City of Ramsey as part of a wrongful abatement of Defendant's Ramsey property <br />