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STATE OF MINNESOTA <br /> <br />COUNTY OF ANOKA <br /> <br />Tomco Real Estate Associates, <br />a Minnesota partnership, <br /> <br />Plaintiff, <br /> <br /> VS. <br /> <br />City of Ramsey, a municipal <br />subdivision under the laws <br />of the State of Minnesota, <br /> <br /> Defendant. <br /> <br /> DISTRICT COURT <br />TENTH JUDICIAL DISTRICT <br /> <br />COMPLAINT <br /> <br /> Comes now the Plaintiff, .and for its cause of action against <br />the Defendant States and alleges: <br /> <br />That %he Plaintiff is the equitable owner of the Northwest <br /> <br />Quarter of the Northwest Quarter of Section 23, Township 32, Range <br /> <br />25, Anoka County, Minnesota. <br /> <br />II. <br /> <br /> That the City of ~amsey requires prior approval of any sub.- <br />division of land in the City of Ramsey. <br /> <br />III. <br /> <br />That the Mayor and City Council of the City of Ramsey on <br /> <br />November 27, 1978, refused to permit Plaintiff to subdivide its <br /> <br />property into the following three described parcels: <br /> <br />PARCEL A: <br /> <br />Ail that~part of the Northwest Quarter of the Northwest <br />Quarter of Section 23, Township 32, Range 25, Anoka County, <br />Minnesota, which lies Westerly of the right of Way of <br />County Road No. 57 according to the Anoka County Highway <br />Right of Way Plat No. 1, and East of the West 400 feet of <br />said Northwest Quarter of the Northwest Quarter, said 400 <br />feet being as measured along the North and South lines of <br />said Northwest Quarter of the Northwest Quarter, and <br />Southerly of the following described line: <br /> <br /> Commencing at the Southwest corner of the above <br /> described tract, said point being 400 feet East of <br /> the Southwest corner of said Northwest Quarter of the <br />. Northwest Quarter; thence North 1 degree 13 minutes <br /> 15 seconds West (assumed bearing) along the West line <br /> of the above described tract for a distance of 861.09 <br /> feet to the actual point of beginning of land to be <br /> described; thence South 80 degrees 14 minutes 19 <br /> seconds East to the West line of County Road No. 57 <br /> and there terminating. <br /> <br /> <br />