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LINDQUIST & VENNUM p.ll.p <br />Letter to Clifford M. Greene, Esq <br />November 20, 1998 <br />Page 6 <br />an already existing public road." As evidenced by the 1979 letter of the Chief of <br />Orono Police, Woodhill Avenue, including that portion of the road that dips south <br />east of the Wagener driveway, was policed by the Orono police. Both for decades <br />before and after the construction of the Wagener house in approximately 1958, <br />Woodhill Avenue was plowed through the winter. Decade after decade the gravel <br />road was maintained and graded. Aerial photographs from the 1940's to the present <br />demonstrate the uniform maintenance and surface treatment of the road up to <br />Woodhill's property line. Indeed, Orono ’s own “Official Zoning Map" as revised <br />through June 10, 1998, shows Woodhill Avenue extending to the Woodhill property <br />line. Thus, both maintenance by public authorities and public use establish Woodhill <br />Avenue as a public street up to the Woodhill property line. <br />It would be useful to determine what issues can be narrowed and what facts can be <br />stipulated to prior to embarking on numerous depositions. After you have had an <br />opportunity to review these cases, Mr. Pillsbury's affidavit, and the facts, we should <br />talk. I have begun to assemble various plats and surveys that we discussed so we <br />can come to an agreement on those documents. <br />I am enclosing a set of dated maps showing the parcel locations and assessment <br />numbers of the relevant parcels. I would appreciate it if the City would review these <br />and stipulate to their accuracy. <br />Sincerely. <br />LINDQUIST & VENNUM P.L.L.P. <br />\/\r-— <br />James P. McCarthy <br />\ <br />JPMcilms <br />enclosure <br />DiKtt I0744S01