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I <br />1 LINDQUIST & VENNUM p. <br />I <br />r <br />r <br />1 <br />[ <br />n <br />I►. t <br />I <br />i <br />i <br />P.L.L.P. <br />IN Denver <br />4200 IDS C enter U noquist . vennum & C^iR stensen <br />80 SCw'^H Eighth S'R£E* PLLP <br />Minneapolis Minnesota 5S402-220S 600 17th Street . Suite 2125 <br />Telephone 6i2*37i.32ii Denver .C olorado 80202*5401 <br />A ttorneys A t Law <br />James IV McCarthy <br />((»I2)37|.323H <br />jmccanhyiu lindquist com <br />November 20.1998 <br />Clifford M. Greene. Esq. <br />Greene Espel <br />333 South Seventh Street <br />Suite 1700 <br />Minneapolis, Minnesota 55402 <br />Re: Woodhill Country Club v. City of Orono, et at. <br />Court File No. 98-10541 <br />Dear Cliff: <br />I am writing to follow-up on our telephone conversation of last week. You had <br />inquired about a stipulation as to certain documents and facts. While willing to <br />stipulate to facts, I also inquired whether the issues in the lawsuit could be <br />narrowed. <br />At the commencement of the action. I understood that the parties disagreed as to <br />the requirements of the conditional use permit ordinance. I believe that continues to <br />be the only substantive issue between the parties. I was surprised to find Orono <br />taking the position that Woodhill Avenue has never been a public street up to the <br />Woodhill property line. My client is aware of no facts which support that position. <br />Since the City has raised the issue. I have looked into both the law concerning the <br />topic and begun the process of gathering evidence. I strongly believe that, if you <br />review that law and information, you will agree the issue should be dropped from the <br />lawsuit. Rather than just leave a few cites on your voice mail, I thought it may be <br />productive to share my legal and factual research in almost memo-like form. <br />Docs IO74480M