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AFFIRMATIVE DEFENSES <br />Defendant Kiefer asserts the following affirmative defenses. <br />1. Isanti County's Complaint fails to state a claim upon which relief can be granted. <br />2. Isanti County as a political subdivision, under the estoppels and other legal <br />doctrines, cannot bring this Complaint against Defendant when another political subdivision City <br />of Ramsey has caused the violative conditions on Defendant's property. <br />3. Isanti County's complaint propounds an illegality in light of the prior conviction <br />of Defendant for conditions wrongfully caused on the property by the City of Ramsey. <br />4. Isanti County's complaint is barred by res judicata and collateral estoppel <br />consequences of the Anoka County District Court Findings of Fact, Conclusions of Law and <br />Order for Judgment filed June 17, 2011. <br />5. The City of Ramsey contributed to the violative condition of Defendant's <br />property legally excusing Defendant's purported violations. <br />6. Isanti County's complaint must be dismissed for lack of joining the City of <br />Ramsey as a necessary party. <br />7. Any judgment entered against Kiefer in favor of Isanti County should be adjudged <br />against the City of Ramsey and its City Administrator so that Kiefer owes nothing. <br />THIRD PARTY COMPLAINT <br />The Keith Kiefer for his Third Party Complaint alleges as follows: <br />Third Party Plaintiff. <br />1. Third Party Plaintiff Keith Kiefer owns the property at 559 McKnight Road <br />South, Saint Paul, Minnesota, 55119. <br />4 <br />