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f-m■A-: <br />f. <br />i-;.>4. 1 <br />f <br />E-v <br />P <br />L.AW OrC'CES <br />SIEGEL. 3RILL. GREUPNEP & DUF'^'V. o a <br />g»ossman -aplins SiCOCL a apiL^ <br />hichaao sicccu <br />jOSiah C. aWlLC. wA <br />jAMCS m CACUPNCA <br />gcpalo s ourrv <br />WOOD m roSTCP <br />THOMAS M GOODMAN <br />K. CPAIO wruOTANC <br />JOHN a MTATSON <br />WM. CHSISTOPMCP PCNWCLL <br />SUSAN M VOIGT <br />I(ATHLCCN a. CONNCLL^ <br />STCVCN U. SCNCCHTMAN* <br />ANTHONY J. GLCCKKL <br />SHCnPl L POHLT <br />SSIAN C. WCISSCPO <br />MIN <br />SU'TC 3SO <br />• OO WASHINGTON SOUAPE <br />POLIS. MINNESOTA 55-^01 <br />TCLEPmCNC 339 Ti3r <br />’'ELECCP'CP '6*8' 339 »i59* <br />■“Tcsru ^ <br />‘TccCBA5sesrT <br />December 27, 1990 <br />CERTIFIED MAIL <br />RETURN RECEIPT REQUESTED <br />l.h- <br />JL <br />16,793-JW <br />Mr. Mark Bernhardson <br />City Administrator <br />City of Orono <br />1335 South Brown Road <br />Orono, MN 55323 dec 2 S ^ <br />Cuff Drainage Problem <br />Dear Hark: <br />On December 28, 1989, on behalf of my clients, Mark and <br />Karen Cuff ("Cuffs"), I made a formal demand on the City of <br />Orono ("City") fc the construction of a storm drain in the <br />Navarre Heights s Jadivision west of County Road 19 and north <br />of County Road 15. This demand was made to prevent <br />litigation and to solve a severe water drainage problem in <br />the Navarre Heights neighborhood. As you know, the Cuffs <br />met with the City on several occasions, and appeared at many <br />City Council meetings in pursuit of a drainage system for <br />the Navarre Heights neighborhood. It was the cuff's hope <br />that the storm sewer would solve the water drainage problem <br />and prevent any damage to their home. Unfortunately, during <br />the painful process of trying to receive approval for the <br />storm sewer, the Cuff's property has suffered severe water <br />damage. <br />In order to establish the cause and effect of the water <br />damage to their property,, the Cuffs retained a mechanical, <br />structural and geotechnical engineer. The engineer in his <br />evaluation of the Cuff's property, concluded that the <br />basement structure of the Cuff's home has suffered severe <br />water-related stress damage. The engineer further concluded <br />that the damage is the result of surface waters and ground <br />AkMiitaiMaAiiii