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State of Minnesota(City of Orono)v.Paul J.Pascuzzi <br /> STATEMENT OF PROBABLE CAUSE <br /> Melanie Curtis, Planning and Zoning Coordinator for the City of Orono,being duly <br /> swom,makes Complaint to the above-named Court and says that she believes this information, <br /> and other persons from whom it is obtained, to be reliable and that there is probable cause to <br /> believe that the above-named Defendant committed the offense(s) described below. The <br /> Complainant states that the followi.ng facts establish probable cause: <br /> Defendant is the owner of real property located at 3320 Navarre Lane, Orono, Minnesota <br /> ("the subject property"). The subject property is located inside the Orono city limits and is zoned <br /> �or residential use. <br /> On September 14, 201 l, City inspectors observed that the subject property's lawn had not <br /> been mowed and an unregistered and inoperable boat, license MN 0645 DV,was stored on the <br /> exterior of the property in violation of Orono City Code Section 78-1577(a)(4). On September <br /> 28, 2011,the City mailed Defendant a letter notifying Defendant that the subject property was <br /> not in compliance with provisions of the Orono City Code and listed the City Code violations <br /> that needed to be addressed. The correspondence further stated that the lawn had to be mowed <br /> and the boat licensed to the property and operable, stored in an enclosed structure, or removed <br /> from the property by October 10,2011. <br /> On September 20,2011, City staff learned that the boat stored on the subject property <br /> was last registered to Therese Catherine Kantos. <br /> On October 10 and November 11, 2011, City inspectors again observed that the boat had <br /> not been registered to the property made operable,moved for storage in an enclosed structure, or <br /> removed from the property. On November 29, 2011, the City mailed Defendant a second letter <br /> notifying him that exterior storage of the inoperable and unregistered boat was prohibited by the <br /> Orono City Code. The correspondence further stated that the boat had to be registered to the <br /> property and operable, stored in an enclosed structure, or removed from the property by <br /> December 12, 2011. <br /> On November 30, 201 l, City staff received a telephone call from Ms. Kantos' husband, <br /> who stated that she has been deceased for three and a half years. <br /> On December 12, 2011, City inspectors observed that the boat had not been registered to <br /> the property made operable,moved for storage in an enclosed structure, or removed from the <br /> property. <br /> 161870v1 2 <br />