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, . Page 2 STATEMENT OF PROBABLS CAIISE The Complainant states that the following facts establish probable cause: Your complainant is a Planning and Zoning Coordinator for the City of Orono. The condition of the property located at 3320 Navarre Lane, in the City of Orono, County of Hennepin, and State of Minnesota ("Subject Property") , was identified as having City Code violations that needed to be corrected. City records reveal that the subject property is owned by PAUL JAMES PASCUZZI, DOB: 07/29/1959, the defendant above-named. The subject property is zoned residential. On July 2, 2012, City inspectors observed exterior accumulations of junk, scrap materials, and trash on the subject property in violation of Orono City Code § 78-1577 (6) . On July 6, 2012, the City mailed defendant a letter notifying him that the subject property was not in compliance with Orono City Code § 78-1577. The letter instructed defendant to bring the subject property into compliance by removing the miscellaneous junk from the property or storing it in an enclosed structure by July 20, 2012 . The letter also informed defendant that failure to do so may result in criminal prosecution. On July 20, 2011, City staff reinspected the subject property and observed that the aforementioned violations had not been corrected. On August 1, 2012, the City mailed defendant a second correction letter outlining the violations and establishing a compliance date of August 13, 2012 . On August 13, 2012, City staff reinspected the property and observed that the junk accumulation remained on the subject property. On August 28, 2012, the City mailed Defendant a final notice instructing defendant to bring the subject property into compliance by September 11, 2012. On September 11, 2012, and October S, 2012, City staff reinspected the property and observed that the aforementioned violations had not been corrected.