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JURISDICTION AND VENUE <br /> 4. The Court has personal jurisdiction over Pagonis because she is a Minnesota <br /> resident. <br /> 5. Venue is proper because the City and Pagonis both reside in Hennepin County. <br /> THE CONTROVERSY <br /> 6. The City maintains that City Ordinances prohibit dock and slip rental and that it <br /> prohibits any rental business in a residential district. <br /> 7. Upon information and belief Pagonis has rented at least eight different dock <br /> spaces and slips to individuals. Upon inspection, Pagonis had eight boats along her dock and in <br /> dock slips that were neither owned nor registered to Pagonis. <br /> 8. The City provided notice to Pagonis of her violation of City Ordinances on June <br /> 15, 2003. The City provided Pagonis notice that she was to remove all boats that were not <br /> licensed or registered to her. <br /> 9. Pagonis has not removed said boats and is refusing to comply with City <br /> Ordinances. <br /> 10. As a result of this dispute and disagreement between the City and Pagonis <br /> regarding their respective rights and obligations, there exists a real and judiciable controversy <br /> ripe for adjudication by the Court. <br /> WHEREFORE, Plaintiff the City of Orono respectfully prays that the Court enter <br /> judgment in favor of the City and against Pagonis as follows: <br /> a. Finding Pagonis is violation of City Ordinances by illegally renting boat slips and <br /> dock space and permitting boats not licensed or registered to her to dock at her property; <br /> 2 <br /> 121096360v1 754868 <br />