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27-CV-25-2808 <br />Filed in District Court <br />State of Minnesota <br />2/15/2025 12:08 PM <br />57. The Orono City Council's adoption of Resolution No. 7554 is either an error, a <br />wrongful act, or both. <br />58. City Clerk Lusian's current or future act of scheduling, arranging, or <br />administering a special election on May 13, 2025 is an error or wrongful act that has <br />happened or is about to happen. <br />IV. Absent This Court's Intervention, a Special Election Will Be <br />Unlawfully Held on May 13, 2025. <br />59. Resolution No. 7554 "orders a special municipal election to be held on Tuesday, <br />May 13, 2025." Dickey Aff. Ex. N. <br />60. Resolution No. 7554 also orders actions relating to the May 13 special election <br />to be completed by Orono officials and employees, by law under the authority of the <br />Orono City Clerk, Orono, Minnesota, City Code, Title I, Chapter 2, Article IV, Section <br />2-145(b), and the dates on or by which those and other actions are to be commenced <br />or completed. Dickey Aff. Ex. N. <br />61. These actions, whether they have already taken place or are about to take <br />place, are errors and wrongful acts which may be corrected pursuant to Minn. Stat. § <br />62. This Court's intervention is necessary to correct and prevent completed and <br />imminent unlawful acts and errors. <br />13 <br />68 <br />