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HomeMy WebLinkAboutUntitled • • LAW OFFICES OF `i Eckherg, Lammers, Briggs, Wolff & Vierling, P.L.L.P. 1835 Northwestern Avenue Lyle J. Eekberg Stillwater. Minnesota 55082 Susan D. Olson James F. Lammers (612) 439-2878 David K. Snyder Robert G. Briggs** FAX (612) 439-2923 Mark J. Vierling* Direct Dial (612) 351-2118 Paul A Wolff Gregory G. Galley (1911-1996) Kevin K. Shoeberg *Qualified Xeutral Arbirator& Mediator Thomas J. Weidner October 7, 1996 *Qualified Neutral Arbitrator *Certified Real Estate Specialist WASHINGTON COUNTY COURT ADMINISTRATOR CIVIL COURT DIVISION WASHINGTON COUNTY GOV'T CENTER 14900 61ST STREET NORTH STILLWATER MN 55082 RE: In the Matter of the Condemnation of Certain Lands in the City of Oak Park Heights Court File No. C6-96-1745 Dear Administrator: Enclosed herewith for filing please find Notice of Entry and Filing of Report of Commissioners together with our Affidavit of Service in regards to the above-referenced matter. Also enclosed please find the proposed Final Certificate which we would ask that you forward to Judge Eggleston for his approval. If you have any questions or concerns regarding this, please feel free to contact me directly. Yours very truly, Mark J. Vierling MJV/smp Enclosure cc: Mr. Michael Robertson � ~ Mr. Karl Ranum ' i e . STATE OF MINNESOTA IN DISTRICT COURT COUNTY OF WASHINGTON TENTH JUDICIAL DISTRICT CASE TYPE: CONDEMNATION City of Oak Park Heights, a Court File No. C6-96-1745 municipal corporation, Petitioner, NOTICE OF ENTRY AND vs. FILING OF REPORT OF COMMISSIONERS Allan A. Connel, Jr. and Geraldine Connel, husband and wife, Respondent . • TO: Allan A. Connel, Jr. and Geraldine Connel, husband. and wife, and their attorney, Karl Ranum, 104 North Main Street, Stillwater, MN 55082 PLEASE TAKE NOTICE that in the above-entitled matter, the Report of the Commissioners, which is attached hereto, was filed with the Washington County Court Administrator' s Office. The award of the Court-Appointed Commissioners may be appealed to the District Court by any party having any interest in the subject property if the award is considered to be unsatisfactory. If an appeal is taken, it must be filed with the Clerk of District Court within forty (40) days from the date the Report is entered, and must conform with all of the requirements as set forth in Minnesota Statutes Chapter 117. If you do not wish to appeal the award and wish payment of the award prior to the expiration of the forty (40) day appeal period, you may request a waiver of appeal form from our office. If no appeal is taken by either the Petitioner or any of the other parties in interest, and a waiver of appeal form is not a . • executed, the Petitioner will, within approximately two (2) weeks after the expiration of the forty (40) day appeal period, deliver a check payable to Allan A. Connel, Jr. and Geraldine Connel, husband and wife in the amount of the award, less amounts previously paid, plus interest as set forth in Minnesota Statutes Chapter 117, to the following person: Karl A. Ranum, Attorney At Law, addressed to him at 104 N. Main Street, Stillwater, MN 55082 . The check must be endorsed by all parties named on the face of the check. Dated this 7th day of October , 1996 . ECKBERG, LAMMERS, BRIGGS, WOLFF & VIERLING, P.L.L.P. /s/ Mark J. Vierling Mark J. Vierling Attorneys for Plaintiff 1835 Northwestern Avenue Stillwater, MN 55082 (612) 439-2878 Attorney I .D. 112823 • • STATE OF MINNESOTA IN DISTRICT COURT COUNTY OF WASHINGTON TENTH JUDICIAL DISTRICT CASE TYPE: CONDEMNATION City of Oak Park Heights, a Court File No. C6-96-1745 municipal corporation, Petitioner, REPORT OF COMMISSIONERS IN vs. THE MATTER OF THE CONDEMNATION OF CERTAIN LANDS IN THE CITY Allan A. Connel, Jr. and OF OAK PARK HEIGHTS Geraldine Connel, husband and wife, Respondent. The undersigned, WILLIAM A. SCHWAB, Chairman, JAMES K. MUGG and CLIFFORD N. ADKINS, Commissioners duly appointed by the above Court to ascertain and report the amount of damage that will be sustained by the above-named owner of the land described in the Petition on file herein by reason of taking by condemnation of that certain parcel of land described as follows : SEE ATTACHED hereby report as follows : That the Commissioners, having qualified as required by law, having viewed the premises taken and having heard the testimony relative thereto, hereby assess and award the following damages for the taking of the real property interests described therein: Damages for the taking are assessed in the amount of $ ,2E)/, lsz ca (*) • The undersigned further report that they have spent the number of days shown below in the discharge of their duties as Commissioners, and ask as their fees the amounts hereinafter stated . , • 111 for the performance of said duties as Commissioners in accordance with the provisions of the Order by which they were appointed as follows : WILLIAM A. SCHWAB Fees at $ /5-60• " per day for days . $ 7 5b, C'c, JAMES K. MUGG Fees at $ /.j o, v° per day for `T" days. CLIFFORD N. ADKINS Fees at $ /60. C c' per day for days. $ G00. C' The undersigned, in their discretion, allow and show separately in addition to the above award of damages, reasonable appraisal fees in the amount of $ 500. Con Dated this off"---;- day of 9��,� �-�c ' ' , Penfield, Inc. 10010 60th Str. No,Stillwater, MCI 55032 WILLIAM A. SCHWAS .4tYl..ta, k Woodland Acres 10336 Jody Amin No, Stillwater, MST 55082 MMES K. MUGG Cf Adkins Appraisal Service 2227 Lake Flip Ave No, CL I FE RD N. ADKINS Take Elan, NN 55042 . . EXHIBIT A All that part of the South 225 .00 feet of the Northeast Quarter of the Northwest Quarter of Section 4, Township 29 North, Range 20 West, Washington County, Minnesota, described as follows : Beginning at the point of intersection of the northerly line of said South 225 .00 feet with the easterly line of the West 332.00 feet of said Northeast Quarter of the Northwest Quarter; thence easterly along said northerly line 209.79 feet, more or less, to Y , the easterly li ne of that particular parcel as described on Certificate of Title Number 3188, as the same is on file and of record in the office of the Registrar of Titles in and for said Washington County, Minnesota; thence southerly along said easterly line 223 .35 feet, more or less, to a point 1.73 feet northerly, as • measured along said easterly line, from the southerly line of said northeast Quarter of the Northwest Quarter; thence westerly in a direct line to a point in said easterly line of the West 332 .00 feet of the Northeast Quarter of the Northwest Quarter distant 0 .57 feet northerly, as measured along said easterly line, from said southerly line of Northeast Quarter of the Northwest Quarter; thence northerly alon g said easterly line to the point of beginning. Parcel contains 1.0781 acres, more or less. Subject to easements and agreements of record. Subject to and together with any other valid easements, reservations or restrictions. • co ej,„11 • LAW OFFICES OF ECKBERG, LAMMERS, BRIGGS, WOLFF Sc VIERLING, P.L.L.P. 1835 NORTHWESTERN AVENUE STILLWATER. MINNESOTA 55082 (612)439-2878 FAX(612)439-2923 LYLE J. ECKBERG GREGORY G. GALLER JAMES F. LAMMERS KEVIN K. SHOEBERG ROBERT G. BRIGGS THOMAS J.WEIDNER PAULA.WOLFF Direct Dial (612) 351-2118 SUSAN D.OLSON MARK J.VIERLING _... ■ulp K a NYI7R�....,..__ September 10, 1996 1T SEP 1 21996 MR ROGER ROHRER ?... .- _..... BETTENDORF ROHRER KNOCHE & WALL INC -- SUITE 314 1600 UNIVERSITY AVENUE ST PAUL MN 55104 RE: In the Matter of the Condemnation of Certain Lands in the City of Oak Park Heights Dear Roger: For what it is worth, I am forwarding you a copy of the appraisal that was prepared on the Connel property by Curt Remington as directed by attorney Karl Ranum. The hearing in this matter, as you know, is set f y t or September 20, 1996, I believe that you have all the documents with regard to surveys and other matters that have been prepared in this matter to date, but if not, please let me know and we will forward them to you. Also, I trust that you have calendared out the Commissioner' s hearing date and plan to attend. Yours very truly, Mark J. Vierling MJV/smp Enclosure cc: Mr. Michael J. Robertson bps : Please also calendar this time on your calendar as well . We will need your testimony at the same time. • STATE OF MINNESOTA IN DISTRICT COURT COUNTY OF WASHINGTON TENTH JUDICIAL DISTRICT CASE TYPE: CONDEMNATION City of Oak Park Heights, a Court File No. C6-96-1745 municipal corporation, Petitioner, FINDINGS OF FACT, CONCLUSIONS vs . OF LAW AND ORDER APPOINTING COMMISSIONERS Allan A. Connel, Jr. and Geraldine Connel, husband and wife, Respondent . IN THE MATTER OF THE CONDEMNATION OF CERTAIN REAL ESTATE IN THE COUNTY OF WASHINGTON, STATE OF MINNESOTA, FOR PARK USE, BIKE AND WALKWAY UTILIZATION, TO THE ABOVE-NAMED RESPONDENT (S) : The above-entitled matter came on for hearing before the undersigned Judge of the above-named Court on the 7th day of August, 1996, at the Washington County Government Center in the City of Stillwater, on the Petition of the City of Oak Park Heights, a municipal corporation under the laws of the State of Minnesota, for an Order of this Court adjudging that the proposed taking by condemnation of that certain parcel of land in the City of Oak Park Heights, Washington County, Minnesota, described as follows : SEE ATTACHED for park use, bike and walkway utilization purposes, is a public use, is authorized by law and is necessary; appointing Commissioners to appraise the damages occasioned by such proposed taking, fixing the time and place of the first meeting of Commissioners and providing for said Commissioners' compensation. . • James F. Lammers, of Eckberg, Lammers, Briggs, Wolff & Vierling, P.L.L. P. , Stillwater, Minnesota, appeared as counsel on behalf of the Petitioner, City of Oak Park Heights . Karl M. Ranum appeared on behalf of the Respondent. Petitioner thereupon offered in evidence the Petition in the above-entitled proceedings, together with notices in the proceedings and proof of service of the notices, which Petition, Notices and proofs of service were received and admitted into evidence . Evidence was thereafter received as to the necessity for the taking. The Court, having heard all competent evidence in support of the granting of the Petition and there being no evidence offered in opposition to the granting of the Petition, finds as follows : FINDINGS OF FACT I. That the notice of the object of the Petition and of the time andplace of the hearing, as required by law, was duly served upon the Respondents herein, as appears more fully by the Affidavits of Service on file. II. That the Court has jurisdiction over the subject of the proceedings and of the land described in the Petition. III. That the City of Oak Park Heights is a municipal corporation created and existing under the laws of the State of Minnesota. 4 s Iv. That the proposed taking is necessary, is for public use and is authorized by law. The Court further finds as : CONCLUSIONS OF LAW That the proposed taking, insofar as this parcel is concerned, is necessary and as such is authorized by law. IT IS THEREFORE ORDERED, that Clifford N. Adkins William A. Schwab and James K. Mugg and Norman Davis and John T. Kenna as alternates, each of whom is a disinterested person and resident of Washington County, Minnesota, are hereby appointed as Commissioners to ascertain and report the amount of damages that will be sustained by the respective owners of the parcel of land described in the Petition herein, on account of such taking. IT IS FURTHER ORDERED, that the first meeting of said Commissioners shall be heard in the offices of the Court Administrator of Washington County, in the County Government Center at Stillwater, Minnesota on the 14th day of August, 1996 , at 9 : 00 o' clock a.m. , on that date; that the compensation of each of said Commissioners shall be, and hereby is, fixed at the sum of One Hundred Fifty Dollars ($150 . 00) per day for each and every day served by him in the performance of his duties as a Commissioner. IT IS FURTHER ORDERED, that the estate acquired by Petitioner, its successors and assigns, in the parcel more particularly described in the Petition on file herein, shall be a partial or a • • permanent taking of said parcel of land as designated in the Petition for park use, bike and walkway utilization purposes. Dated this 7 day of 4,, , 1996 . Ju•ge of District a -like 411 411 EXHIBIT A All that part of the South 225 . 00 feet of the Northeast Quarter of the Northwest Quarter of Section 4, Township 29 North, Range 20 West, Washington County, Minnesota, described as follows : Beginning at the point of intersection of the northerly line of said South 225 . 00 feet with the easterly line of the West 332 .00 feet of said Northeast Quarter of the Northwest Quarter; thence easterly along said northerly line 209 .79 feet, more re or less, to the easterly line of that particular parcel as described on Certificate of Title Number 3188, as the same is on file and of record in the office of the Registrar of Titles in and for said Washington County, Minnesota; thence southerly along said easterly line 223 . 35 feet, more or or less, to a point 1.73 feet northerly, as measured along said easterly line, from the southerly line of said northeast o"uarter Q of the Northwest uarter; thence westerly y in a direct line to a point in said easterly line of the West 332 . 00 feet of the Northeast Quarter of the Northwest Quarter distant 0 . 57 feet e northerly, as measured along said easterly line, from said southerly line of Northeast Quarter of the Northwest Quarter; thence northerly along said easterly line to the . Y 4 y point of . be innin 4 4 Parcel contains 1. 0781 acres, more or less. Subject to easements and agreements of record. Subject to and together with any other valid easements, , reservations or restrictions. i • C(11 'y LAW OFFICES OF ECKBERG, LAMMERS, BRIGGS, WOLFF $c VIERLING, P.L.L.P. 1835 NORTHWESTERN AVENUE STILLWATER, MINNESOTA 55082 (612)439-2878 FAX(612)439-2923 LYLE J. ECKBERG GREGORY G.GALLER JAMES F. LAMMERS KEVIN K. SHOEBERG ROBERT G. BRIGGS THOMAS J.WEIDNER PAULA.WOLFF Direct Dial (612) 351-2118 SUSAN D.OLSON MARK J.VIERLING DAVID K.SNYDER July 30, 1996 WASHINGTON COUNTY COURT ADMINISTRATOR CIVIL COURT DIVISION WASHINGTON COUNTY GOV' T CENTER 14900 61ST STREET NORTH STILLWATER MN 55082 RE: In the Matter of the Condemnation of Certain Lands in the City of Oak Park Heights Court File No. C6-96-1745 Dear Administrator: Enclosed herewith for filing please find Proposed Commissioner Nominees together with our Affidavit of Service in regards to the above-referenced matter. Yours very truly, Mark J. Vierling MJV/smp Enclosure cc: Mr. Michael Robertson • LAW OFFICES OF Lid ECKBERG, LAMMERS, BRIGGS, WOLFF & VIERLING, P.L.L.P. 1835 NORTHWESTERN AVENUE STILLWATER. MINNESOTA 55082 (612)439.2878 FAX (612)439-2923 LYLE J. ECKBERG GREGORY G.CALLER JAMES F. LAMMERS KEVIN K.SHOEBERG ROBERT G. BRIGGS THOMAS J.WEIDNER PAULA.WOLFF Direct Dial (612) 351-2118 SUSAN 0.OLSON MARK J.VIERLING DAVID K.SNYDER July 30, 1996 MR ALLAN A CONNEL JR MS GERALDINE CONNEL 14303 N 60TH STREET OAK PARK HEIGHTS MN 55082 MR KARL M RANUM ATTORNEY AT LAW • 104 NORTH MAIN STREET STILLWATER MN 55082 RE: Connel Park Acquisition Dear Mr. and Mrs. Connel and Mr. Ranum: Enclosed herewith and served upon you by U. S . Mail please find Proposed Commissioner Nominees in regards to the above- referenced matter. Yours very truly, s/I Mark J. Vierling MJV/smp Enclosure cc: Mr. Michael Robertson ! • STATE OF MINNESOTA IN DISTRICT COURT COUNTY OF WASHINGTON TENTH JUDICIAL DISTRICT CASE TYPE: CONDEMNATION City of Oak Park Heights, a Court File No. municipal corporation, Petitioner, PROPOSED vs. COMMISSIONER NOMINEES Allan A. Connel, Jr. and Geraldine Connel, husband and wife, Respondents . IN THE MATTER OF THE CONDEMNATION OF CERTAIN REAL ESTATE IN THE COUNTY OF WASHINGTON, STATE OF MINNESOTA. TO: DISTRICT COURT above-named, Washington County Government Center, 14900 61st Street North, Stillwater, MN 55082 ; and RESPONDENTS above-named, The Petitioner above-named, through the undersigned, their attorney, respectfully nominate for appointment as Commissioners to ascertain and report the amount of damages that will be sustained by them as a result of the taking by Petitioner above-named, the following competent and disinterested residents of Washington County, to-wit: Nominee Address James Mugg Real Estate Appraiser 10336 Jody Avenue North Stillwater, MN 55082 Michael E. Muske ERA Muske Company 840 West Broadway Forest Lake, MN 55025 Peter Thompson Thompson Property, Inc. 6888 65th Street South Cottage Grove, MN 55016 r . . The undersigned, on behalf of said Petitioner, represent to the Court that they have no relationship, business or otherwise, to any of the nominees above-named and know of no interest in these pending proceedings which may constitute a conflict of interest or which may create the appearance of impropriety should any of the above nominees be appointed. ' Dated this 12th day of July ,, 199. . ECKBERG, LAMME" , BRIGGS, WOLF: & VI. ' ING, P.L.L.P. By -�„�. Mark J. Vierling Atto ey I .D. #112823 Attor y for Petitioner 1835 No thwestern Avenue Stillwater, MN 55082 (612) 439-2878 411 411 LAW OFFICES OF ECKBERG, LAMMERS, BRIGGS, WOLFF & VIERLING, P.L.L.P. 1835 NORTHWESTERN AVENUE STILLWATER, MINNESOTA 55082 (612)439-2878 FAX (612)439-2923 LYLE J. ECKBERG GREGORY G.GALLER JAMES F. LAMMERS KEVIN K. SHOEBERG ROBERT G. BRIGGS THOMAS J.WEIDNER PAUL A.WOLFF Direct Dial (612) 351-2118 SUSAN D. OLSON MARK J.VIERLING DAVID K. SNYDER July 12, 1996 MR MICHAEL J ROBERTSON CITY ADMINISTRATOR JUL CITY OF OAK PARK HEIGHTS ,� `UL 1 51996 H, P 0 BOX 2007 I' 14168 57TH STREET NORTH '1 OAK PARK HEIGHTS MN 55082 - RE : Connel Park Acquisition Court File No. C6-96-1745 Dear Mike : Enclosed herewith please find an Amended Notice in the Matter of the Condemnation of Certain Lands in the City of Oak Park Heights, Petition and Notice of Lis Pendens in the above entitled matter. This matter is set before Judge Eggleston on -•ust 1996 at 9 : 00 a.m. and I am requesting that you be press t at than time to testify. I will be on vacation at that t ' e, howev , I have arranged for Jim Lammers to take my place . If you have any questions, please feel fr-e to contact my office . Yours v-ry uly, Mar J. Vierling -- MJV/smp Enclosures 411 STATE OF MINNESOTA IN DISTRICT COURT COUNTY OF WASHINGTON TENTH JUDICIAL DISTRICT CASE TYPE: CONDEMNATION City of Oak Park Heights, a Court File No. C6-96-1745 municipal corporation, Petitioner, AMENDED NOTICE IN THE MATTER OF vs . THE CONDEMNATION OF CERTAIN LANDS IN THE CITY OF OAK Allan A. Connel, Jr. and PARK HEIGHTS Geraldine Connel, husband and wife, Respondent. TO: Allan A. Connel, Jr. and Geraldine Connel, husband and wife, 14337 60th Street North, Oak Park Heights, MN 55082 You are hereby notified that on the 7th day of August, 1996, Y Y g at 9 : 00 o' clock a.m. , or as soon thereafter as Counsel can be heard in the Washington County Government Center in Stillwater, Minnesota, Petitioner will present to the District Court, Tenth Judicial District, a Petition, a copy of which is served herewith for the condemnation of certain lands to be used for park use, bike and walkway utilization. The object of said Petition is to acquire real property for park use, bike and walkway utilization of the land described as follows : SEE ATTACHED EXHIBIT A Also Petitioner will ask the Court to appoint Commissioners to ascertain and report the amount of damage that will be sustained by the Respondent land owner and encumbrances on account of such taking. The lands and rights proposed to be so taken are situated in . the City of Oak Park Heights, County of Washington, Minnesota, are described and the names of all persons appearing on record known to Petitioner to be the owner of said lands or having any rights or interest therein, including all whom your Petitioner has been able to discover by inquiry or investigation, together with the nature of ownership of each as nearly as can be ascertained, are set forth as follows : Allan A. Connel, Jr. Geraldine Connel Dated this 12th day of July, 1996 . ECKBERG, ERS, BR S, WOLFF & VIERLD , P.L - .P. Mar J. Vierling At■orneys for Petitioner Ci. of Oak Park Heights 1835 orthwestern Avenue Stillwater, MN 55082 (612) 439-2878 Attorney I .D. 112823 • • STATE OF MINNESOTA IN DISTRICT COURT COUNTY OF WASHINGTON TENTH JUDICIAL DISTRICT CASE TYPE: CONDEMNATION City of Oak Park Heights, a municipal corporation, Petitioner, PETITION IN THE MATTER OF vs . THE CONDEMNATION OF CERTAIN LANDS IN THE CITY OF OAK Allan A. Cannel, Jr. and PARK HEIGHTS Geraldine Connel, husband and wife, Respondent. Petitioner, the City of Oak Park Heights, alleges as follows : I . That the Petitioner is duly incorporated City organized and existing under and by virtue of the laws of the State of Minnesota, and as such is authorized to exercise the right of eminent domain pursuant to the provisions of Chapter 117 of Minnesota Statutes. II . The City of Oak Park Heights held a regular meeting of the City Council of the City on April 8, 1996, said City Council determined it to be necessary and proper for the City to acquire access rights to the land described as follows : SEE ATTACHED EXHIBIT A all of which is located in said City, County, and State, and the names of all persons appearing of record or known to be the owners of said lands or interested therein, including all those whom Petitioner has ascertained by investigation and inquiring, together with the nature of the ownerships and interests, as nearly as can S • be determined are hereinafter set forth: III . That none of said lands are presently devoted to public use except as hereinafter expressly stated. WHEREFORE, Petitioner, City of Oak Park Heights, prays: a. That such proceedings may be had as is provided by law and that Petitioner acquire by condemnation the interests for the purposes hereinabove stated in said lands as against Respondents as hereinafter set forth; b. That it be adjudged and determined that the use for which such lands are sought to be taken as a public use and that this g P taking is authorized by law; c . That three competent and disinterested persons who are residents of Washington County, Minnesota, be appointed as Commissioners to ascertain and report the amount of damages that will be sustained by the owners and other persons interested in said land; d. That the Court fix the time and place of the first meeting of such commissioners and prescribe compensation; e . That the Commissioners be directed and instructed by the Court to proceed according to law and to make a fair and impartial assessment and award of damages sustained by Respondent herein by reason of Petitioner' s taking of the lands hereinafter described and to report the same to the Court, and in all cases where, for any reason, it shall be doubtful to whom the award shall be paid, that such amount be paid to the Clerk of Court to be paid out by 2 • o him under the direction of the Court; f . And for such other and further relief as may be appropriate in the premises. Dated this 7717 day of _- / , 1996 . ECKBERG, RS, BRI : , WOLFF & VIE- 'G, P.L.L Miark J. Vierlincf • Attgxneys for Petitioner City of Oak Park Heights 1835 Northwestern Avenue Stillwater, MN 55082 (612) 439-2878 Attorney T.D. 112823 3 • s EXHIBIT A All that part of the South 225 .00 feet of the Northeast Quarter of the Northwest Quarter of Section 4, Township 29 North, Range 20 West, Washington County, Minnesota, described as follows: Beginning at the point of intersection of the northerly line of said South 225 .00 feet with the easterly line of the West 332 . 00 feet of said Northeast Quarter of the Northwest Quarter; thence easterly along said northerly line 209 . 79 feet, more or less, to the easterly line of that particular parcel as described on Certificate of Title Number 3188 , as the same is on file and of record in the office of the Registrar of Titles in and for said Washington County, Minnesota; thence southerly along said easterly line 223 . 35 feet, more or less, to a point 1. 73 feet northerly, as measured along said easterly line, from the southerly line of said northeast Quarter of the Northwest Quarter; thence westerly in a direct line to a point in said easterly line of the West 332 . 00 feet of the Northeast Quarter of the Northwest Quarter distant 0 .57 feet northerly, as measured along said easterly line, from said southerly line of Northeast Quarter of the Northwest Quarter; thence northerly along said easterly line to the point of beginning. Parcel contains 1.0781 acres, more or less. Subject to easements and agreements of record. Subject to and together with any other valid easements, reservations or restrictions. • . EXTRACT OF MINUTES OF MEETING OF THE CITY COUNCIL OF THE CITY OF OAK PARK HEIGHTS, WASHINGTON COUNTY, MINNESOTA HELD: April 8, 1996 Pursuant to due call and notice thereof, a regular meeting of the City Council for the City of Oak Park Heights, Washington County, Minnesota was duly held at the City within said City- on the 8th day of April, 1996, at 7 :00 o'clock p.m. The following members were present: Mayor: Barbara H. O'Neal Councilperson: David Schaaf Councilperson: Dean Kern Councilperson: Mark Swenson The following members were absent: Councilperson: Janet Robert Member Schaaf introduced the following Resolution and moved its adoption: RESOLUTION NO. 96-04-10 CITY OF OAR PARK HEIGHTS RESOLUTION AUTHORIZING THE INITIATION OF EMINENT DOMAIN PROCEEDINGS AND/OR NEGOTIATION OF ACQUISITION OF PARKLAND/WALKWAY AND BIXEPATE EASEMENTS AFFECTING THE ALLAN A. CONNEL, JR. AND GERALDINE CONNEL PROPERTY WHEREAS, the City wishes to acquire real property for the purpose of locating park improvements and/or bike and walkway improvements necessary for the development of the City- park system serving all residents within the City of Oak Park Heights with such acquisitions being areas adjacent to and over lands owned by Allan A. Connel, Jr. and Geraldine Cannel, husband and wife; and, WHEREAS, the City has determined that the required improvements are necessary to provide for a reasonable park system and provide for the public welfare and safety of the residents of the City of Oak Park Heights. NOW, THEREFORE, BE IT RESOLVED by the City Council for the City of Oak Park Heights, Washington County, Minnesota as follows : • • • 1. That staff and legal counsel are hereby authorized to • initiate condemnation/eminent domain proceedings to acquire real property for park use, bike and walkway utilization over and affecting property owned by Allan A. Cannel, Jr. and Geraldine Cannel, husband and wife so as to secure such property to facilitate the development of park properties within the City of Oak Park Heights and to serve existing park structures and park improvements adjacent to said property as the same is affected thereby with such property being legally described in Exhibit A and annexed hereto and incorporated herein by reference. 2. That the staff and legal counsel are authorized to take all necessary steps to acquire possession of the subject property pursuant to Minnesota Statutes §117.01 et seq. 3 . That pursuant to this Resolution duly adopted by the City Council and in the interest of public safety and welfare, it is understood that the City employees and agents may be required to enter upon the lands as may be necessary to perform surveying and appraisal activities related to the improvements to be constructed thereon. Whereupon said Resolution was declared duly seconded by member Kern and upon vote being taken thereon, the following voted via voice: Four • And the following voted against same: None Whereupon said Resolution was declared duly passed and adopted. • r f • STATE OF MINNESOTA COUNTY OF WASHINGTON ) ss . CITY OF OAK PARK HEIGHTS ) I, the undersigned, being the duly qualified and acting Administrator of the City of Oak Park Heights, Minnesota, DO HEREBY CERTIFY that I have compared the attached and foregoing extract of minutes with the original thereof on file in my office, and that the same is a full, true and complete transcript of the minutes of a meeting of the City Council of said City, duly called and held on the date therein indicated insofar as such minutes of a meeting of the City Council of said City, duly called and held on the date therein indicated insofar as such minutes relates to the resolution of the City of Oak Park Heights authorizing the initiation of Eminent Domain/Condemnation proceedings and/or the negotiation of easements affecting the Allan A. Connel, Jr. and Geraldine Connel property. WITNESS my hand and the seal of said City this 7 day of 4/o4../ 192.L. r Michael Ro•er son (SEAL) City Administrator • f + 411 • 86102 STA'E OF MINNESOTA IN DISTRICT COURT COUNTY OF WASHINGTON TENTH JUDICIAL DISTRICT CASE TYPE: CONDEMNATION City of Oak Park Heights, a Court File No. municipal ,corporation, `-1 Petitioner, vs . NOTICE OF LIS PENDENS Allan A. Connel, Jr. and Geraldine Connel, husband and wife, Respondent's. NOTICE IS HEREBY GIVEN, that an action has been commenced in the above-named Court against the Respondents in the action above described, said Respondents being the owners of certain lands in said City of Oak Park Heights described as follows: • SEE ATTACHED The purpose of said action is for the condemnation of said lands for park use, bike and walkway utilization; that the Petitioner is to take the access to the lands described herein and have exclusive control of the same, that upon appointment of the Commissioners to ascertain and report the amount of damage that will be sustained by the respondents in the action above described, Petitioner will, at the earliest time authorized by law, take possession of the premises affected by this action, which premises are situated in the County of Washington, State of Minnesota, said lands being described as follows : SEE ATTACHED i Dated this Q Z' day of 49,-r."/ , 1996 . ECKBERG, ERS, BRIGGS, WOLFF VIE NG, P.L.L. P. By. Avp■ Mask J. Vierling Attorneys for Petitioner 1835 Northwestern Avenue Stillwater, MN 55082 (612) 439-2878 This instrument was drafted by: Mark J. Vierling Eckberg, Lammers, Briggs, Wolff & Vierling, P.L.L.P. 1835 Northwestern Avenue Stillwater, MN 55082 (612) 439-2878 • EXHIBIT A All that part of the South 225 . 00 feet of the Northeast Quarter of the Northwest Quarter of Section 4 , Township 29 North, Range 20 West, Washington County, Minnesota, described as follows : Beginning at the point of intersection of the northerly line of said South 225 . 00 feet with the easterly line of the West 332 . 00 feet of said Northeast Quarter of the Northwest Quarter; thence • easterly along said northerly line 209 .79 feet, more or less, to the easterly line of that particular parcel as described on Certificate of Title Number 3188, as the same is on file and of record in the office of the Registrar of Titles is and for said Washington County, Minnesota; thence southerly along said easterly line 223 . 35 feet, more or less, to a point 1 . 73 feet northerly, as measured along said easterly line, from the southerly line of said northeast Quarter of the Northwest Quarter; thence westerly in a direct line to a point in said easterly line of the West 332 . 00 feet of the Northeast Quarter of the Northwest Quarter distant 0 . 57 feet northerly, as measured along said easterly line, from said southerly line of Northeast Quarter of the Northwest Quarter; thence northerly along said easterly line to the point of beginning. Parcel contains 1 . 0781 acres, more or less . Subject to easements and agreements of record. Subject to and together with any other valid easements, reservations or restrictions. • Sheet 2 of 2 Sheets CERTIFICATE OF SURVEY BARRETT M. STACK STILLWATER, MINN. 55082 MINNESOTA REGISTERED LAND SURVEYOR Tel. No. 439-5630 SURVEY MADE EXCLUSIVELY FOR: The City of Oak Park Heights , c/o Mark Vierling , Attorney , 1835 Northwestern Avenue , Stillwater , Minnesota 55082 DESCRIPTION: All of the following described parcels are part of an overall parcel as desc . on Cert. of Title No . 3188, fee owner : Allan A. and Geraldine F . Connell . Proposed Description of portion of N-S-P Easement Contained in Cert . Title No . 3188 : All that part of the South 225 .00 feet of the Northeast Quarter of the Northwest Quarter of Section 4 , Township 29 North , Range 20 West , Washington County , Minnesota , described as follows : Beginning at the point of intersection of the northerly line of said South 225 . 00 feet with the the easterly line of the West 332 .00 feet of said Northeast Quarter of the Northwest Quarter ; thence easterly along said northerly line 209 . 79 feet , more or less , to the easterly line of that particular parcel as described on Certificate of Title Number 3188 , as the same is on file and of record in the office of the Registrar of Titles in and for said Washington County , Minnesota ; thence southerly along said easterly line 223 . 35 feet , more or less , to a point 1 .73 feet northerly , as measured along said easterly line , from 0 the southerly line of said Northeast Quarter of the Northwest Quarter ; thence westerly in a direct line to a point in said easterly line of the West 332 .00 feet of the Northeast Quarter of the Northwest Quarter distant 0 . 57 feet northerly , as measured along said easterly line , from said southerly line of Northeast Quarter of the Northwest Quarter ; thence northerly along said easterly line to the point of beginning . Parcel contains 1 . 0781 acres , more or less . Subject to easements and agreements of record . Subject to and together with any other valid easements , reservations or restrictions . Proposed Public Walkway Permanent and Temporary Easement Description : A 10 .00 foot wide Permanent Easement and a 20 .00 foot wide Temporary Construction Easement, all for Public Walkway purposes , over , under and across all that part of the South 225 .00 feet of the Northeast Quarter of the Northwest Quarter of Section 4 , Township 29 North , Range 20 West , Washington County , Minnesota , the common centerline of both easements being described as follows : Beginning at point in the easterly line of the West 332 , 00 feet of said Northeast Quarter of the Northwest Quarter , distant 182 .00 feet southerly , as measured along said easterly line , from the northerly line of said South 225 . 00 feet of the Northeast Quarter of the Northwest Quarter ; thence easterly in a direct line , along said common centerlines , 209 . 93 feet, more or less , to a point in the easterly line of that particular parcel as described on Certificate of Title Number 3188, as the same >. s on file and of record in the office of the Registrar of Titles in and for said Washington County , Minnesota , said point being 186 .00 feet southerly , as measured along said g d easterly line , from said northerly line of the South 225 .00 feet of said Northeast Quarter of the Northwest Quarter , said oint also being the P 9 end of the common centerlines being described . The sidelines of said Permanent 10 . 00 foot wide Easement , and the sidelines of said 20.00 foot wide Temporary Construction Easement being shortened or prolonged as to terminate on said easterly line of the West 332 .00 feet of the Northeast Quarter of the Northwest Quarter , and being shortened or prolonged as to terminate on said easterly line of said parcel described on Certificate of Title Number Subject to easements and agreements of record . Subject to and together with any other valid easements , reservations or restrictions . Proposed Tennis Court Encroachment Easement Parcel : An easement for Public Tennis Court ur oses over , under and across all that part of the South 225 .00 feet of the Northeast Quarter of the Northwest Quarter of Section 4 , Township 29 North , Range 20 West, Washington County, Minnesota , described as follows : Commencing at the point of intersection of the northerly line of said South 225 .00 feet of the Northeast Quarter of the Northwest Quarter , with the easterly line of that particular parcel as described on Certificate of Title Number 3188 , as the same is on file and of record in the office of the Registrar of Titles in and for said Washington County , Minnesota ; thence South 01 degree 04 minutes 15 seconds East, assumed bearing , along said easterly line , 41 . 00 feet to the point of beginning of the easement being described ; thence North 89 degrees 39 minutes 32 seconds West 17 . 00 feet ; thence South 00 degree 20 minutes 28 seconds West 129 .00 feet; thence South 89 degrees 39 minutes 32 seconds East 20 . 18 feet , more or less , to said easterly line of the parcel described on Certificate of Title Number 3188 ; thence North 01 degree 04 minutes 15 seconds West, along said easterly line, 129 .04 feet , more or less , to the point of beginning . , Easement contains 2398 square feet, or 0 .0551 acre , more or less . Subject to easements and agreements of record . Subject to and together with any other valid easements , reservations or restrictions . NOTES : Note 0. 28 ' t description gap between the e ' ly . line of the parcel described of Cert. of Title No. 3188 , and p � I hereby certify that this survey, Il an, or rc F „rt «a5 the westerly lin e of Reg . Land Survey No. 76 , which prepared by me or under m direct supervision and that adjoins e 1 Fee owner of P P Y Y E 0 this S desc . I am a duly Registered or under he lau s of J Y • gap area not y g Land Survey t known or ascertained in the course of this survey . the State of Minnesota. III (see Sheet 1 of 2 Sheets for details of desc . gap) /,:- Date Jan . 23 , 1996 Re .No 13774 g • • pyLAW OFFICES OF ECKBERG, LAMMERS, BRIGGS, WOLFF 8c VIERLING, P.L.L.P. 1835 NORTHWESTERN AVENUE STILLWATER. MINNESOTA 55082 1612)439-2878 FAX(612)439-2923 LYLE J. ECKBERG GREGORY G. GALLER JAMES F. LAMMERS KEVIN K.SHOEBERG ROBERT G. BRIGGS THOMAS WEIDNER PAUL A.WOLFF Direct Dial (612) 351-2118 SUSAN O..OLSON MARK J.VIERLING DAVID K.SNYDER April 12, 1996 MR KARL M RANUM ATTORNEY AT LAW • 104 NORTH MAIN STREET STILLWATER MN 55082 • RE: Connel Park Acquisition Dear Mr. Ranum: Enclosed herewith and served upon you by U. S. Mail please find Petition in the Matter of Condemnation of Certain Lands in the City of Oak Park Heights, Notice in the Matter of Certain Lands in the City of Oak Park Heights and Notice of Lis Pendens in regards to the above-referenced matter. Also enclosed please find an -Acceptance of Service form which we would ask that you sign and return back to our office as soon as possible. If you have any questions regarding this, please feel free to contact me directly. Yours very truly, X71 Mark J. Vierling MJV/smp Enclosure cc: Mr. Michael Robertson - . _ _ • • LAW OFFICES OF ECKBERG, LAMMERS, BRIGGS, WOLFF & VIERLING, P.L.L.P. '835 NORTHWESTERN AVENUE STILLWATER, MINNESOTA 55082 (612)439-2878 FAX(612)439-2923 LYLE J. ECKBERG GREGORY G.GALLER JAMES F. LAMMERS KEVIN K.SMOEBERG ROBERT G. BRIGGS Direct Dial (612) 351-2118 THOMAS J.WEIONER PAUL A.WOLFF SUSAN 0. OLSON MARK J.VIERLING DAVID K. SNYDER April 12, 1996 MR ROGER ROHRER BETTENDORF ROHRER KNOCHE & WALL INC SUITE 314 1600 UNIVERSITY AVENUE ST PAUL MN 55104 RE: In the Matter of the Condemnation of Certain Lands in the City of Oak Park Heights Dear Roger: Enclosed herewith please find documents regarding the acquisition of certain lands in the City of Oak Park Heights for parkland, bike and walkway use. Please review same and contact me so that we may coordinate timing as it relates to Commissioner hearings, reports, etc. Yours very truly, (7/ Mark J. Vierling MJV/smp Enclosures cc: Mr. Michael J. Robertson "� • • ` , LAW OFFICES OF ,F /- ECKBERG, LAMMERS, BRIGGS, WOLFF $c VIERLING, P.L.L.P. Lf( 117 1835 NORTHWESTERN AVENUE STILLWATER, MINNESOTA 55082 (612)439-2878 FAX (612)439-2923 LYLE J. ECKBERG GREGORY G.GALLER JAMES F. LAMMERS KEVIN K.SHOEBERG ROBERT G. BRIGGS THOMAS J.WEIDNER PAUL A.WOLFF SUSAN D.OLSON MARK J. VIERLING DAVID K.SNYDER April 12, 1996 WASHINGTON COUNTY RECORDER WASHINGTON COUNTY GOV'T CENTER 14900 61ST STREET NORTH STILLWATER MN 55082 RE: In the Matter of the City of Oak Park Heights vs. Allan A. Cannel, Jr. and Geraldine Connel, husband and wife Court File No. C6-96-1745 Dear Madam: Enclosed herewith for recording please find Notice of Lis Pendens together with our firm check in the amount of $19 .50 to cover the cost of the recording fee in this regard. If there is anything additional that is required, please feel free to contact my office. • Yours very truly, Mark J. Vierling MJV/smp Enclosure cc: Mr. Michael Robertson "� • • r73 V LAW OFFICES OF C Ii ECKBERG, LAMMERS, BRIGGS, WOLFF & VIERLING, P.L.L.P. 1835 NORTHWESTERN AVENUE STILLWATER, MINNESOTA 55082 (612)439-2878 FAX(612)439-2923 LYLE J. ECKBERG GREGORY G.GALLER JAMES F. LAMMERS KEVIN K. SHOEBERG ROBERT G. BRIGGS THOMAS J.WEIDNER PAUL A.WOLFF Direct Dial (612) 351-2118 SUSAN O.OLSON MARK J.VIERLING DAVID K.SNYDER April 9, 1996 • WASHINGTON COUNTY COURT ADMINISTRATOR CIVIL COURT DIVISION WASHINGTON COUNTY GOV'T CENTER 14900 61ST STREET NORTH STILLWATER MN 55082 RE: In the Matter of the Condemnation of Certain Lands in the City of Oak Park Heights Dear Administrator: Enclosed herewith for filing please find Petition in the Matter of the Condemnation of Certain Lands in the City of Oak Park Heights together with our firm check in the amount of $132 . 00 to cover the cost of the filing fee in this regard. Please put this matter on for judicial assignment as soon as possible and notify my office of same so that I may schedule this matter for hearing. If there is anything further that you require, please feel free to contact my office. Yours very truly, Mark J. Vierling MJV/smp Enclosures cc: Mr. Michael Robertson . STATE OF MINNESOTA IN DISTRICT COURT COUNTY OF WASHINGTON TENTH JUDICIAL DISTRICT CASE TYPE: CONDEMNATION City of Oak Park Heights, a municipal corporation, Petitioner, PETITION IN THE MATTER OF vs . THE CONDEMNATION OF CERTAIN LANDS IN THE CITY OF OAK Allan A. Connel, Jr. and PARR HEIGHTS Geraldine Connel, husband and wife, Respondent. Petitioner, the City of Oak Park Heights, alleges as follows: I. That the Petitioner is duly incorporated City organized and existing under and by virtue of the laws of the State of Minnesota, and as such is authorized to exercise the right of eminent domain pursuant to the provisions of Chapter 117 of Minnesota Statutes. II . The City of Oak Park Heights held a regular meeting of the City Council of the City on April 8, 1996, said City Council determined it to be necessary and proper for the City to acquire access rights to the land described as follows : SEE ATTACHED EXHIBIT A all of which is located in said City, County, and State, and the names of all persons appearing of record or known to be the owners of said lands or interested therein, including all those whom Petitioner has ascertained by investigation and inquiring, together with the nature of the ownerships and interests, as nearly as can ' • • be determined are hereinafter set forth: III . That none of said lands are presently devoted to public use except as hereinafter expressly stated. WHEREFORE, Petitioner, City of Oak Park Heights, prays: a. That such proceedings may be had as is provided by law and that Petitioner acquire by ire b condemnation the interests for the purposes hereinabove stated in said lands as against Respondents as hereinafter set forth; b. That it be adjudged and determined that the use for which such lands are sought to be taken as a public use and that this taking is authorized by law; c. That three competent and disinterested persons who are residents of Washington County, Minnesota, be appointed as Commissioners to ascertain and report the amount of damages that will be sustained by the owners and other persons interested in said land; d. That the Court fix the time and place of the first meeting of such commissioners and prescribe compensation; e . That the Commissioners be directed and instructed by the Court to proceed according to law and to make a fair and impartial assessment and award of damages sustained by Respondent herein by reason of Petitioner' s taking of the lands hereinafter described and to report the same to the Court, and in all cases where, for any reason, it shall be doubtful to whom the award shall be paid, that such amount be paid to the Clerk of Court to be paid out by 2 • him under the direction of the Court; f . And for such other and further relief as may be appropriate in the premises. Dated this r day of 10 "- / , 1996 . l ECKBERG, RS, BRI : , WOLFF & VIER 1G, P.L.L ' . M-rk J. Vierli • A. orneys for Petitioner City of Oak Park Heights 1835 Northwestern Avenue Stillwater, MN 55082 (612) 439-2878 Attorney I .D. 112823 3 4 • EXHIBIT A All that part of the South 225 . 00 feet of the Northeast Quarter of the Northwest Quarter of Section 4 , Township 29 North, Range 20 West, Washington County, Minnesota, described as follows : Beginning at the point of intersection of the northerly line of said South 225 . 00 feet with the easterly line of the West 332 . 00 feet of said Northeast Quarter of the Northwest Quarter; thence easterly along said northerly line 209 . 79 feet, more or less, to the easterly line of that particular parcel as described on t 1 Certificate of Title Number 3 88, as t he same is on file and of record in the office of the Registrar of Titles in and for said Washington County, Minnesota; thence southerly along said easterly line 223 . 35 feet, more or less, to a point 1 .73 feet northerly, as measured along said easterly line, from the southerly line of said northeast Quarter of the Northwest Quarter; thence westerly in a direct line to a point in said easterly line of the West 332 .00 feet of the Northeast Quarter of the Northwest Quarter distant 0 .57 feet northerly, as measured along said easterly line, from said southerly line of Northeast Quarter of the Northwest Quarter; thence northerly along said easterly line to the point of beginning. Parcel contains 1. 0781 acres, more or less. Subject to easements and agreements of record. Subject to and together with any other valid easements, reservations or restrictions. S • EXTRACT OF MINUTES OF MEETING OF THE CITY COUNCIL OF THE CITY OF OAK PARK HEIGHTS, WASHINGTON COUNTY, MINNESOTA HELD: April 8, 1996 Pursuant to due call and notice thereof, a regular meeting of the City Council for the City of Oak Park Heights, Washington County, Minnesota was duly held at the City within said City on the 8th day of April, 1996, at 7:00 o' clock p.m. The following members were present: Mayor: Barbara H. O'Neal Councilperson: David Schaaf Councilperson: Dean Kern Councilperson: w ounce person: Mark Swenson • The following members were absent: Councilperson: Janet Robert Member Schaaf introduced the following Resolution and moved its adoption: • RESOLUTION NO. 96-04-10 CITY OF OAK PARK HEIGHTS RESOLUTION AUTHORIZING THE INITIATION OF EMINENT DOMAIN PROCEEDINGS AND/OR NEGOTIATION OF ACQUISITION OF PARKLAND/WALKWAY AND BIKEPATH EASEMENTS AFFECTING THE ALLAN A. CONNEL, JR. AND GERALDINE CONNEL PROPERTY • WHEREAS, the City wishes to acquire real property for the • purpose of locating park improvements and/or bike and walkway improvements necessary for the development of the City park system serving all residents within the City of Oak Park Heights with such acquisitions being areas adjacent to and over lands owned by Allan A. Connel, Jr. and Geraldine Connel, husband and wife; and, WHEREAS, the City has determined that the required improvements are necessary to provide for a reasonable park system and provide for the public welfare and safety of the residents of the City of Oak Park Heights . NOW, THEREFORE, BE IT RESOLVED by the City Council for the City of Oak Park Heights, Washington County, Minnesota as follows : • • 1 . That staff and legal counsel are hereby authorized to initiate condemnation/eminent domain proceedings to acquire real property for park use, bike and walkway utilization over and affecting property owned by Allan A. Connel, Jr. and Geraldine Connel, husband and wife so as to secure such property to facilitate the development of park properties within the City of Oak Park Heights and to serve existing park structures and park improvements adjacent to said property as the same is affected thereby with such property being legally described in Exhibit A and annexed hereto and incorporated herein by reference. 2 . That the staff and legal counsel are authorized to take all necessary steps to acquire possession of the subject property pursuant to Minnesota Statutes §117.01 et seq. 3 . That pursuant to this Resolution duly adopted by the City Council and in the interest of public safety and welfare, it is understood that the City employees and agents may be required to enter upon the lands as may be necessary to perform surveying and appraisal activities related to the improvements to be constructed thereon. Whereupon said Resolution was declared duly seconded by member Kern and upon vote being taken thereon, the following voted via voice: Four And the following voted against same: None Whereupon said Resolution was declared duly passed and adopted. • 411 . STATE OF MINNESOTA COUNTY OF WASHINGTON ) ss. CITY OF OAK PARK HEIGHTS ) I, the undersigned, being the duly qualified and acting Administrator of the City of Oak Park Heights, Minnesota, DO HEREBY CERTIFY that I have compared the attached and foregoing extract of minutes with the original thereof on file in my office, and that the same is a full, true and complete transcript of the minutes of a meeting of the City Council of said City, duly called and held on the date therein indicated insofar as such minutes of a meeting of the City Council of said City, duly called and held on the date therein indicated insofar as such minutes relates to the resolution of the City of Oak Park Heights authorizing the initiation of Eminent Domain/Condemnation proceedings and/or the negotiation of easements affecting the Allan A. Connel, Jr. and Geraldine Connel property. WITNESS my hand and the seal of said City this l9`5 day of +as? , 1974 . /51'7 Michael Ro•er son (SEAL) City Administrator . • • 0 Py's LAW OFFICES OF ECKBERG, LAMMERS, BRIGGS, WOLFF & VIERLING, P.L.L.P. 1835 NORTHWESTERN AVENUE STILLWATER, MINNESOTA 55082 (612)439-2878 FAX (612)439-2923 LYLE J. ECKBERG GREGORY G.GALLER JAMES F. LAMMERS KEVIN K.SHOEBERG ROBERT G. BRIGGS Direct Dial (612) 351-2118 THOMAS J.WEIDNER PAUL A.WOLFF SUSAN D.OLSON MARK J.VIERLING DAVID K.SNYGER April 11, 1996 MR KARL M RANUM ATTORNEY AT LAW 104 NORTH MAIN STREET STILLWATER MN 55082 RE: Connel Park Acquisition Dear Mr. Ranum: Pursuant to my correspondence with you of April 3, 1996, I am enclosing herewith the City' s check made payable to your office in the amount of $300 . 00 . This is provided you pursuant to Minn. Stat. §117 .232 as reimbursement per our agreement on the appraisal that has been conducted by your office on behalf of Mr. and Mrs. Connel. Yours very truly, 5/ Mark J. Vierling MJV/smp Enclosure cc: Mr. Michael Robertson L r t 411 110 STATE OF MINNESOTA IN DISTRICT COURT COUNTY OF WASHINGTON TENTH JUDICIAL DISTRICT CASE TYPE: CONDEMNATION City of Oak Park Heights, a Court File No. C6-96-1745 municipal corporation, Petitioner, NOTICE IN THE MATTER OF vs. THE CONDEMNATION OF CERTAIN LANDS IN THE CITY OF OAK Allan A. Cannel, Jr. and PARK HEIGHTS III Geraldine Connel, husband and wife, Respondent. TO: Allan A. Connel, Jr. and Geraldine Connel, husband and wife, 14337 60th Street North, Oak Park Heights, MN 55082 You are hereby notified that on the 6th day of June, 1996, at 9 :00 o'clock a.m. , or as soon thereafter as Counsel can be heard in the Washington County Government Center in Stillwater, Minnesota, Petitioner will present to the District Court, Tenth Judicial District, a Petition, a copy of which is served herewith for the condemnation of certain lands to be used for park use, bike and walkway utilization. The object of said Petition is to acquire real property for park use, bike and walkway utilization of the land described as follows : SEE ATTACHED EXHIBIT, A Also Petitioner will ask the Court to appoint Commissioners to ascertain and report the amount of damage that will be sustained by the Respondent land owner and encumbrances on account of such taking. The lands and rights proposed to be so taken are situated in • 411 110 the City of Oak Park Heights, County of Washington, Minnesota, are described and the names of all persons appearing on record known to Petitioner to be the owner of said lands or having any rights or interest therein, including all whom your Petitioner has been able to discover by inquiry or investigation, together with the nature of ownership of each as nearly as can be ascertained, are set forth as follows : Allan A. Connel, Jr. Geraldine Connel Dated this 9j day of �4 ,�,.`/ , 1996 . ECKBERG, RS, : `IGGS, WOLFF & VIE' G, P. .P. Ma } J. Vierling Att., eys for Petition-r City of Oak Park Heights 1835 Northwestern Avenue Stillwater, MN 55082 (612) 439-2878 Attorney I .D. 112823 it EXHIBIT A All that part of the South 225 . 00 feet of the Northeast Quarter of the Northwest Quarter of Section 4 , Township 29 North, Range 20 West, Washington County, Minnesota, described as follows : Beginning at the point of intersection of the northerly line of said South 225 .00 feet with the easterly line of the West 332 .00 feet of said Northeast Quarter of the Northwest Quarter; thence easterly along said northerly line 209. 79 feet, more or less, to the easterly line of that particular parcel as described on Certificate of Title Number 3188, as the same is on file and of record in the office of the Registrar of Titles in and for said Washington County, Minnesota; thence southerly along said easterly line 223 .35 feet, more or less, to a point 1.73 feet northerly, as measured along said easterly line, from the southerly line of said northeast Quarter of the Northwest Quarter; thence westerly in a direct line to a point in said easterly line of the West 332 . 00 feet of the Northeast Quarter of the Northwest Quarter distant 0 .57 feet northerly, as measured along said easterly line, from said southerly line of Northeast Quarter of the Northwest Quarter; thence northerly along said easterly line to the point of beginning. Parcel contains 1.0781 acres, more or less. Subject to easements and agreements of record. Subject to and together with any other valid easements, reservations or restrictions . Page 2 - Minutej104/08/96 S rategic Planning Committee - Councilmember Schaaf reported on the first Strategic Planning Committee meeting. The purpose of the meeting was to explore the possibility for cost savings through sharing joint services between the cities of Bayport and Oak Park Heights and Baytown Township. The Committee will make recommendations on this issue to the City Councils . Mayor O'Neal noted the next meeting will be Thursday, June 6 at 7 : 00 p .m. at Bayport Library. Oak Park Heights Business Group - Councilmember Schaaf and Administrator Robertson reported they met with the Stillwater Area Chamber of Commerce to discuss the possibility of organizing an Oak Park Heights business group as part of the Stillwater Area Chamber of Commerce. St . Croix River Bridge Meeting - Mayor O'Neal reported that she and Administrator Robertson attended a MNDOT meeting regarding the new St . Croix River bridge and viewed a computer simulation of how the view would look driving across the bridge . Mayor O'Neal said there were also representatives from the Bridge Coalition, Chamber of Commerce, Sierra Club, and NSP at the meeting. Consent Agenda • Approve Minutes - March 25, 1996 • Set Public Hearing Date - May 13, 1996 Request for Variance - Robert and Lydia Wood - Construction of an Additional Garage • Set Public Hearing - May 13, 1996 - Ordinance Amendment 96- 1016-01 - An Ordinance Amending the City Parking Ordinance • Set Public Hearing - April 22, 1996 - Outdoor Recreation Grant • Resolution 96-04-09 - A Resolution Authorizing Participation in the 4M Money Market Fund • Resolution 94-04-10 - A Resolution Authorizing the Initiation of Eminent Domain Proceedings and/or Negotiation and Acquisition of Parkland/Walkway and Bike path Easements Affecting the Allan A. Connel, Jr. and Geraldine Connel Property Councilmember Schaaf, seconded by Kern, moved to approve the Consent Agenda as presented. Carried 4-0 . League of Minnesota Cities Leadership Seminar - Mayor O'Neal distributed material she received at the Leadership Seminar. Any questions regarding the material can be directed to Administrator Robertson. • , LAW OFFICES OF ECKBERG, LAMMERS, BRIGGS, WOLFF & VIERLING, P.L.L.P. LLLIII 1835 NORTHWESTERN AVENUE STILLWATER,MINNESOTA 55082 (612)439-2878 FAX(512)439-2923 LYLE J. ECKBERG GREGORY G.GALLER JAMES F. LAMMERS KEVIN K. SHOEBERG ROBERT G. BRIGGS THOMAS J.WEIDNER PAULA.WOLFF Direct Dial (612) 351-2118 SUSAN D. OLSON MARK J. VIERLING DAVID K.SNYDER April 3, 1996 MR KARL RANUM 1J 15 ATTORNEY AT LAW 104 NORTH MAIN STREET APR - 5 STILLWATER MN 55082 RE: Connel Park Acquisition Dear Mr. Ranum: I am in receipt of your appraisal that you obtained from Mr. Remington. Pursuant to Minn. Stat. §117 . 232 I will advise the City Council to authorize reimbursement for the appraisal fees incurred up to $300 . 00 as you have proposed. That check will be directly issued by the City of Oak Park Heights and forwarded to your office. Unfortunately, I cannot utilize Mr. Remington' s appraisal as a basis of negotiation with the Connels in this matter inasmuch as. Mr. Remington has neither noted nor has he accounted for the fact that the area of the powerline easement is not buildable. Nonetheless, he has assigned full value on a per square foot basis for the powerline easement area as if it were buildable . Consequently, the City will obtain its own appraisal on this matter and proceed forward as time and process require that we do so. Please advise us as to whether or not you will accept service of the Petition for Condemnation on behalf of your clients . Yours very truly, Mark J. Vierling MJV/smp cc : Mr. Michael Robertson " Mayor Barbara H. O'Neal • • • • Enclosure 10 LAW OFFICES OF ECKBERG, LAMMERS, BRIGGS, WOLFF & VIERLING, P.L.L.P. 1835 NORTHWESTERN AVENUE STILLWATER, MINNESOTA 55082 (612)439-287B FAX (612)439-2923 LYLE J. ECKBERG GREGORY G.GALLER JAMES F. LAMMERS KEVIN K.SHOEBERG ROBERT G. BRIGGS THOMAS J.WEIDNER PAUL A.WOLFF SUSAN D.OLSON MARK J.VIERLING DAVID K. SNYDER Direct Dial (612) 351-2118 February 5, 1996 MR MICHAEL J ROBERTSON CITY ADMINISTRATOR RNOTR CITY OF OAK PARK HEIGHTS P 0 BOX 2007 14168 57TH STREET NORTH °' 6I OAK PARK HEIGHTS MN 55082 CITY OF RE: City of Oak Park Heights OAK PARK HEIGHTS Connel Park Acquisition Dear Mike : As you can see, the City has now received the Certificate of Survey from Mr. Stack, I am asking that Mr. Stack' s bill be authorized for payment and I, of course, have copied you on my correspondence to Mr. Ranum. My time table that I would propose to have this matter dealt with would be for the City to complete its negotiations for voluntary purchase from Mr. Connel on or before the end of February, if Mr. Connel is not willing to conclude transactions along those lines at that time, I would that I be authorized to complete acquisition by way of eminent domain which, I believe, the council previously authorized, but which I would like to have reaffirmed at the 2nd meeting in February. There is also the need to have an appraisal done on this property, but for purposes of private negotiations with the Connels, I would prefer to see if we could select a joint appraiser that everyone would agree with before we go out and secure an appraisal for the condemnation process, if that is necessary. If you have any questions in this mat -r, p1-:se feel free to contact me directly. Yours ver ruly, Maik J. Vier ing MJV/smp Enclosures • • LAW OFFICES OF ECKBERG, LAMMERS, BRIGGS, WOLFF & VIERLING, P.L.L.P. 1835 NORTHWESTERN AVENUE STILLWATER. MINNESOTA 55082 (612)439-2878 FAX (612)439-2923 LYLE J. ECKBERG GREGORY G. GALLER JAMES F. LAMMERS KEVIN K.SHOEBERG ROBERT G. BRIGGS THOMAS J.WEIDNER PAULA.WOLFF Direct Dial (612) 351-2118 SUSAN D.OLSON MARK J. VIERLING DAVID K. SNYDER February 5, 1996 MR KARL RANUM ATTORNEY AT LAW 104 NORTH MAIN STREET STILLWATER MN 55082 RE: Connel Park Acquisition Dear Mr. Ranum: Mr. Stack has now completed a survey with regard to the City' s needs for parkland acquisition affecting the Connel property. At the same time, I would propose that the City will rectify and acquire that area necessary for the tennis court which is shown to overlap upon the property as well . It may also be an opportune time to meet with neighbors to resolve the issues with regard to the southern portion of the Connel property. One of the options that the City has before it, it to basically acquire not only the walkway easements depicted but the entirety of the area underneath the highline easement going to the south of the Connel property boarder. That, of course, is an option that the City is considering but I think it is appropriate • that you and your client be aware that that matter is under consideration. You will note that I have enclosed sheet 1 of 2 of the Certificate of Survey completed by Mr. Stack, should you have a need for the legal descriptions contained within sheet 2 of the 2, please advise . Yours very truly, el/ Mark J. Vierling MJV/smp Enclosure cc: Mr. Michael Robertson ✓v Sheet 1 of 2 Sheets CERTIFICATE OF SURVEY . BARRETT M. STACK STILLWATER, MINN. 55082 MINNESOTA REGISTERED LAND SURVEYOR Tel. No. 439-5630 JOB N0: None SURVEY MADEEXCLUSIVELY FOR: The City of Oak Park Heights , c/o Mr . Mark Vierling , Atty . , • 1835 Northwestern Avenue , Stillwater , MN 55082 DESCRIPTION: See Sheet 2 of 2 Sheets for overall and easement parcel descriptions : NOTES : Orientation of this bearing system is assumed . o Indicates 1 /2" I . D. Iron Pipe set marked with a plastic plug inscribed RLS 13774 . o Indicates iron pipe , found inplace as noted . Note encroachments as shown and noted hereon . Note description gaps and overlaps as noted hereon . Proposed parcels and easements shown hereon are part of an overall parcel as described on Certificate of Title No . 3188 , fee owner : Allan A. and Geraldine F . Connell . The proposed permanent walkway easement contailns 2099 square feet , more or less . The proposed temporary construction easement contains 2099 square feet , more or less . 411 k 4`X•3r: lONN66 k I E, 1/N6 L.o/t. ,f /,- /' / I/ /' OE.sc,, Gc2r '� is/aT o,sat /4. 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G.r"i✓z% ✓ .E'G -1 /✓�• .`-i MsNdM�Nnro the St* a of Minnesota. y Q Q Date.. Re K'No 1-:2 3'�9.6 13774 9 ill , LLAW OFFICES OF ECKBERG, LAMMERS, BRIGGS, WOLFF & VIERLING, P.L.L.P. 1635 NORTHWESTERN AVENUE STILLWATER. MINNESOTA 55082 (612)439.2878 FAX (612)439-2923 LYLE J. ECKBERG GREGORY G. GALLER JAMES F. LAMMERS KEVIN K. SHOEBERG ROBERT G. BRIGGS THOMAS J.WEIDNER PAUL A.WOLFF Direct Dial (612) 351-2118 SUSAN D.OLSON MARK J.VIERLING DAVID K.SNYDER February 5, 1996 MR KARL RANUM ATTORNEY AT LAW 104 NORTH MAIN STREET STILLWATER MN 55082 RE: Connel Park Acquisition Dear Mr. Ranum: Mr. Stack has now completed a survey with regard to the City' s needs for parkland acquisition affecting the Connel property. At the same time, I would propose that the City will rectify and acquire that area necessary for the tennis court which is shown to overlap upon the property as well. It may also be an opportune time to meet with neighbors to resolve the issues with regard to the southern portion of the Connel property. One of the options that the City has before it, it to basically acquire not only the walkway easements depicted but the entirety of the area underneath the highline easement going to the south of the Connel property boarder. That, of course, is an option that the City is considering but I think it is appropriate that you and your client be aware that that matter is under consideration. You .will note that I have enclosed sheet 1 of 2 of the Certificate of Survey completed by Mr. Stack, should you have a need for the legal descriptions contained within sheet 2 of the 2, please advise. Yours very truly, Mark J. Vierling MJV/smp Enclosure cc : Mr. Michael Robertson • • Enclosure 10 LAW OFFICES OF ECKBERG, LAMMERS, BRIGGS, WOLFF & VIERLING, P.L.L.P. 1835 NORTHWESTERN AVENUE STILLWATER, MINNESOTA 55082 (612)439-2878 FAX(612)439-2923 LYLE J. ECKBERG GREGORY G.GALLER JAMES F. LAMMERS KEVIN K. SHOEBERG ROBERT G. BRIGGS THOMAS J.WEIDNER PAUL A.WOLFF - SUSAN D.OLSON MARK J.VIERLING DAVID K.SNYDER Direct Dial (612) 351-2118 February 5, 1996 MR MICHAEL J ROBERTSON CITY ADMINISTRATOR @ 0 CITY OF OAK PARK HEIGHTS U5 P 0 BOX 2007 14168 57TH STREET NORTH F7 - 6 f _j OAK PARK HEIGHTS MN 55082 CITY OF RE : City of Oak Park Heights OAK PARK HEIGHTS Connel Park Acquisition Dear Mike : As you can see, the City has now received the Certificate of Survey from Mr. Stack, I am asking that Mr. Stack' s bill be authorized for payment and I, of course, have copied you on my correspondence to Mr. Ranum. My time table that I would propose to have this matter dealt with would be for the City to complete its negotiations for voluntary purchase from Mr. Connel on or before the end of February, if Mr. Connel is not willing to conclude transactions along those lines at that time, I would that I be authorized to complete acquisition by way of eminent domain which, I believe, the council previously authorized, but which I would like to have reaffirmed at the 2nd meeting in February. There is also the need to have an appraisal done on this property, but for purposes of private negotiations with the Connels, I would prefer to see if we could select a joint appraiser that everyone would agree with before we go out and secure an appraisal for the condemnation process, if that is necessary. If you have any questions in this mat -r, pl-=se feel free to contact me directly. Yours ver ruly, Mark J. Vier ing MJV/smp Enclosures • • LAW OFFICES OF ECKBERG, LAMMERS, BRIGGS, WOLFF & VIERLING, P.L.L.P. 1835 NORTHWESTERN AVENUE STILLWATER, MINNESOTA 55082 (612)439-2878 FAX(612)439-2923 LYLE J. ECKBERG GREGORY G.GALLER JAMES F. LAMMERS KEVIN K.SHOEBERG ROBERT G. BRIGGS THOMAS J.WEIDNER PAULA.WOLFF Direct Dial (612) 351-2118 SUSAN D.OLSON MARK J.VIERLING DAVID K.SNYDER February 15, 1996 MR KARL RANUM {E C I5 OWE ��1 ATTORNEY AT LAW I ' +� 104 NORTH MAIN STREET • STILLWATER MN 55082 FEB 16 1996 • RE: Connel Park Acquisition Dear Karl : Enclosed herewith please find page two of Barry Stack' s survey. With regard to dealing with your appraiser as I mentioned, I would suggest that you have appraisals prepared in the alternative, i.e. , as follows : (a) Appraise that area that the City wishes specifically for bike/trailpath affecting your client' s property and the area of encroachment of the tennis courts. (b) Appraise the value of that entire area (subject to the NSP highwire easement) from the North line of the NSP highwire easement all the way to the South property line of your client' s property. • At this point in time, I would suspect it is the City' s desire in order to deal with the multitude of issues on this property • between Mr. Connel and his neighbors and the City, that the City • would acquire the entirety of that strip of land lying between the North line of the highwire and your client' s South boundary line. I will withhold any action on my part ordering an appraisal of the property pending receipt from you of Mr. Remington' s appraisal, which I understand should be forthcoming shortly. As I mentioned earlier, the City has a strong interest in acquiring this property early for park development purposes in the spring of 1996 . Consequently, we are anxious to conclude this matter. Yours very truly, Mark J. Vierling MJV/smp Enclosure cc: Mr. Michael Robertson Sheet 2 of 2 Sheets CERTIFICATE OF SURVEY BARRETT M. STACK STILLWATER, MINN. 55082 MINNESOTA REGISTERED LAND SURVEYOR Tel. No. 439-5630 SURVEY MADE EXCLUSIVELY FOR: The City of Oak Park Heights , c/o Mark Vierling , Attorney , 1835 Northwestern Avenue , Stillwater , Minnesota 55082 DESCRIPTION: All of the following described parcels are part of an overall parcel as desc . on Cert. of Title No . 3188, fee owner : Allan A. and Geraldine F . Connell . Proposed Description of portion of N-S-P Easement Contained in Cert . Title No . 3188 : All that part of the South 225 . 00 feet of the Northeast Quarter of the Northwest Quarter of Section 4 , Township 29 North , Range 20 West , Washington County , Minnesota , described as follows : Beginning at the point of intersection of the northerly line of said South 225 . 00 feet with the the easterly line of the West 332 . 00 feet of said Northeast Quarter of the Northwest Quarter ; thence easterly along said northerly line 209 . 79 feet , more or less , to the easterly line of that particular parcel as described on Certificate of Title Number 3188 , as the same is on file and of record in the office of the Registrar of Titles in and for said Washington County , Minnesota ; thence southerly along said easterly line 223 . 35 feet , more or less , to a point 1 . 73 feet northerly , as measured along said easterly line , from the southerly line of said Northeast Quarter of the Northwest Quarter ; thence westerly in a direct line to a point in said easterly line of the West 332.00 feet of the Northeast Quarter of the Northwest Quarter distant 0. 57 feet northerly , as measured along said easterly line , from said southerly line of Northeast Quarter of the Northwest Quarter ; thence northerly along said easterly line to the point of beginning . Parcel contains 1 . 0781 acres , more or less . Subject to easements and agreements of record . Subject to and together with any other valid easements , reservations or restrictions . Proposed Public Walkway Permanent and Temporary Easement Description : A 10 .00 foot wide Permanent Easement and a 20 .00 foot wide Temporary Construction Easement , all for Public Walkway purposes , over , under and across all that part of the South 225 .00 feet of the Northeast Quarter of the Northwest Quarter of Section 4 , Township 29 North , Range 20 West , Washington County , Minnesota , the common centerline of both easements being described as follows : Beginning at point in the easterly line of the West 332 .00 feet of said Northeast Quarter of the Northwest Quarter , distant 182 .00 feet southerly , as measured along said easterly line , from the northerly line of said South 225 . 00 feet of the Northeast Quarter of the Northwest Quarter ; thence easterly in a direct line , along said common centerlines , 209 . 93 feet, more or less , to a point in the easterly line of that particular parcel as described on Certificate of Title Number 3188, as the same is on file and of record in the office of the Registrar of Titles in and for said Washington County , Minnesota , said point being 186 . 00 feet southerly , as measured along said easterly line , from said northerly line of the South 225 .00 feet of said Northeast Quarter of the Northwest Quarter , said point also being the end of the common centerlines being described . The sidelines of said Permanent 10 .00 foot wide Easement , and the sidelines of said 20 .00 foot wide Temporary Construction Easement being shortened or prolonged as to terminate on said easterly line of the West 332 . 00 feet of the Northeast Quarter of the Northwest Quarter , and being shortened or prolonged as to terminate on said easterly line of said parcel described on Certificate of Title Number Subject to easements and agreements of record . Subject to and together with any other valid easements , reservations or restrictions . Proposed Tennis Court Encroachment Easement Parcel : An easement for Public Tennis Court purposes over , under and across all that part of the South 225 .00 feet of the Northeast Quarter of the Northwest Quarter of Section 4 , Township 29 North , Range 20 West, Washington County , Minnesota , described as follows : Commencing at the point of intersection of the northerly line of said South 225 . 00 feet of the Northeast Quarter of the Northwest Quarter , with the easterly line of that particular parcel as described on Certificate of Title Number 3188 , as the same is on file and of record in the office of the Registrar of Titles in and for said Washington County , Minnesota ; thence South 01 degree 04 minutes 15 seconds East, assumed bearing , along said easterly line , 41 . 00 feet to the point of beginning of the easement being described ; thence North 89 degrees 39 minutes 32 seconds West 17.00 feet ; thence South 00 degree 20 minutes 28 seconds West 129 . 00 feet ; thence South 89 degrees 39 minutes 32 seconds East 20 . 18 feet , more or less , to said easterly line of the parcel described on Certificate of Title Number 3188 ; thence North 01 degree 04 minutes 15 seconds West, along said easterly line, 129 .04 feet , more or less , to the point of beginning . Easement contains 2398 square feet , or 0 .0551 acre , more or less . Subject to easements and agreements of record . Subject to and together with any other valid easements , reservations or restrictions . NOTES : Note 0 .28 ' ± description gap between the e ' ly . line of the parcel described of Cert. of Title No . 3188 , and I hereby certify that this survey, plan, or report «as the westerly l i n e of Reg . Land Survey No. 7 6 , which prepared by me or under my direct supervi' on and that adjoins e ' ly . Fee owner of this desc . gap area not I am a duly Registered Land Surveyor under the laws of known or ascertained in the course of this survey . the State of Minnesota. ( see Sheet 1 of 2 Sheets for details of desc . gap) Date Jan . 23 , 1996 13774 Reg.No