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LA)h' C:)F Ir I C Ir e~ <br />ESTES PARSINEN & LEVY <br /> <br /> I00 SOUTH FIRTH <br /> <br /> ~INNEAPOLI~ MINNESOTA ~540~ <br /> <br />November 24, 1987 <br /> <br />Ramsey City Council <br />Ramsey Municipal Center <br />15153 Nowthen Blvd. N.W. <br />Ramsey, Minnesota 55303 <br /> <br />RE: <br /> <br />(Amended) Ramsey County Ordinance No. 170.017M <br />Our File No. 3052-1 <br /> <br />Gentlemen: <br /> <br /> This office represents Art Raudio and H & S Asphalt Co. with respect to the <br />proposed platting of Pineview Estates Third Addition and matters related thereto. We <br />have recently been advised that you have passed the above-entitled ordinance, which <br />ordinance has a direct effect on our clients' platting and grading operations under <br />currently issued permits. ~e have also been informed that the ordinance requires <br />compliance with non-conforming uses within one hundred eighty (150) days of passage. <br />170.017M(!2). <br /> <br /> In our preliminary review, we are convinced that the e._~x post, faet____~o application of an <br />ordinance to existing conditions may not comport with the requirements of due process <br />of law and may constitute an unconstitutional taking of property. Accordingly, on behalf <br />of our clients, we respectfully request that al'., action be taken to permit our clients to <br />proceed under existing conditions and to exempt them from the provisions of the ness' <br />ordinance, in the absence of reasonable measures in this regard, we have been instructed <br />to consider various legal alternatives. <br /> <br />RID/Ips <br />RID-427 <br /> <br />cc: Art !Raudio <br /> Norm Holm <br /> <br />Very tr ,u!y yours, ~_ -- <br />Richard L Diamond <br /> <br /> <br />