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February 24, 1981 <br /> <br />HICKEN lB GEDDE <br />~,TTORNEYS AT L~,W <br /> <br />William K. Goodrich, Ramsey City Attorney <br />211 East Main Street <br />Anoka, MN 55303 <br /> <br />Dear Mr. Goodrich: <br />Please be advised that the undersigned represents David J. Mickelson in an action for <br />dissolution of marriage. <br /> Mr. Miekelson has shown to me today a copy of the unapproved minutes of the meeting of <br /> the Ramsey City Council on February 10, 1981. It appears from these minutes that a <br /> motion brought by Mr. Cox on behalf of Betty Mickelson, my client's wife, to physically <br /> move a building located at ~her" residence to a location at Gateway North Industrial Park <br /> was granted at the meeting. Please be advised that my client had no prior knowledge or <br /> notice of this proceeding and was not present at the aforementioned meeting. <br /> Mr. Mickelson is presently a party to an action for dissolution of marriage. This <br /> proceeding is pending and is not final. In his petition for dissolution of marriage, Mr. <br /> Mickelson has requested that the homestead of the parties located at 16101 Ramsey <br /> Boulevard N.W. be awarded to himself. In this context of this legal proceedings, <br /> ~homestead~ means all buildings and personal property located at 16101 Ramsey <br /> Boulevard N.W. <br /> Since the dissolution action is still pending before the court, all property owned by the <br /> parties, including the ~homestead" remains joint property. You should also know that, in <br /> the temporary order of the court dated October 23, 1980, a copy of which I am attaching <br /> to this letter, Mr. Miekelson was given the full use of the ~shed" (the ~building" referred <br /> to in your minutes), until further order of the court. From the foregoing, it should be <br /> clear that the residence at 16101 Ramsey Boulevard N.W., together with all buildings <br /> located thereon is not the sole property of Betty Mickelson. Indeed the court may well <br /> award the entirety of the homestead property, including the ,~uilding" to Mr. Mickelson <br /> in its final judgment. <br /> As you are mo~t likely aware, Mr. Mickelson's business is operated out of the "building". <br /> The moving of his business to another location would constitute a substantial hardship to <br /> him at this time, and such a moving is strongly objected to. It appears to me that Mrs. <br /> Mickelson is seeking to do by indirection through the actions of the Ramsey City Council <br /> what she cannot do by direction through the court, namely; effecting the disposition of <br /> joint marital property. I might add that the location at Gateway North Industrial Park to <br /> which Mrs. Mickelson seeks removal of this building is a location in which neither Mr. or <br /> Mrs. Mickelson have any kind of a legal interest. <br /> The purp0~e of this letter is to demand that the action of February 10, 1981, mentioned <br /> <br /> <br />