HomeMy WebLinkAboutRe: hazardous property PopxAl� H � 1 � � �
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2400 Or�E Tn BOR C E NTE R S C H N O B R I C H & K A U F M A N. L T D. •�;��� Tow E r.
1200 SEVENTEENTH STREET 222 SOUTH NINTM:iTREET
DENVER,COLORADO BO2O2 MINNEAPOLIS,MINNESOTA 5540�
TE�EPHONE 303-893-1200 �[ TE�/E�vr�oN(E�6(�12-333-4800
TE�ECoaiER303-893-2194 MINNEAPOLIS, MINNESOTA v.�� �E�]7cov1'EllHYL-334-27i3
4100 CENTRUST FINANCIAL CENTER 13001 STREET,N.W.
100 S.E.SECOND STREET SUITE SOO EAST
MIAMI,FIORIDA 33131 WqSHINGTON,D.C.20005
TELEPHONE305-530-0050 SUESAN PAGE-SHAPIRO TE�ePr+oNe202-962-8700
DirxEcr Din�(612) 334-2626
TE�ECOPiER 305-530-0055 TE�ECOPiEw 202-962-B799
September 13 , 1991
Mr . Robert M. Pearson
13005 Main Street
Rogers, MN 55374
Re: Property at 2180 Prospect Avenue,
Orono, Minnesota
Your File No . 3437
Dear Mr . Pearson:
I am in receipt of your letter dated September 10, 1991
concerning the above property.
The City of Orono began inspections of the above property
in October of 1988 . Efforts were made with the property owner
to reach a solution. Unable to do so, the Orono City Council
passed Resolution No . 2521, on October 10 , 1988, requiring
repair or removal of the property above. In February, 1989 an
Order to Raze and Remove Hazardous Building was served on
Mr . Fred Curtis, the owner and Mr . James Thompson, a contract
for deed purchaser . Mr . Thompson had no .permanent address and
it was di�=icult to reach him. Several attempts were made at
locating an address where he could be found and served . As you
are aware, Mr . Curtis had to be served out of state.
Following service, Mr . Curtis sent us a letter dated
February 9 , 1989 , explaining his problems with Mr . Thompson. He
authorized the City to raze the house on the property and "have
the cost become a lien or assessment against the property. " He
also requested that the razing of the building.�,not taken place
until the finalization of the contract for deed cancellation
between Mr . Curtis and Mr . Thompson. In the interim,
Mr. Robert M. 'Pearson
September 12, 1991
Page 2
Mr. Thompson filed for bankruptcy, adding additional
complications to this matter. It must have also caused
complications �n the cancellation of the contract for deed,
because the contract was not cancelled and filing of the
cancellation did not appear until September 12, 1989 .
On October 17, 1989 Orono Deputy City Attorney Benson
Whitney appeared in District Court and obtained a default
judgment to raze and remove the building . The contract was
cancelled, the bankruptcy issues were resolved and the razing
and removal of the structure was performed by the City in March
1990. By Marc� 1990 the City had incurred legal fees in the
amount of $2, 6 0 . 12 .
In ligh� of the complications involved, we feel that the
attorneys fees 'are reasonable.
The City will not discharge its Notice of Lis Pendens as
filed on this property until it is compensated for its egpenses,
including the legal fees . It is my understanding at one point
in time, that the purchaser of the above property had indicated
to City staff inembers that he would pay the fees related to the
hazardous building action. Perhaps you wish to discuss this
matter with him.
In an effort to reach a speedy resolution to this issue,
the City would be willing to delete the $527. 00 in legal fees
which accrued since March of 1990. If the $527 is deleted, the
City expenses are as follows :
Legal Fees $2, 620 . 12 -
Securing building 165 . 72
Burning uilding 500 .00
Debris r moval 3 , 540 . 00
Tot�l $6, 825 . 84
To the e�tent you do not accept this offer by
September 20, 1991, it is withdrawn. We will then seek
compensation for any additional time we spend an this matter,
including the $527 we have agreed to compromise.
, . �
Mr. Robert M. Pearson
September 12, 1991
Page 3
Please contact me once you have had time to consider this
offer.
Very truly yours,
' i��� �
Suesan Pace-Shapiro
Deputy City Attorney
for the City of Orono
SPS/mah .
cc: Ron Moo se, City Administrator ✓
Jeanne abusth
Tom Kue n
Thomas . Barrett
117BNEH
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ORONO
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SUESAN PAGE-SHAPIRO
DiRecr D�a�(612)334-2626
September 27, 1991
Mr . Robert M. Pearson
Robert M. Pearson Law Office
13005 Main Street
Rogers , MN 55374
Re: 2180 Prospect Avenue, Orono, Minnesota
Stipulation for Dismissal
Your File No . 3437
Our File No . 3643-005
Dear Mr . Pearson:
Enclosed please find a proposed Stipulation for Dismissal
for the hazardous building action at 2180 Prospect Avenue. It
is my understanding a check for $6, 963 . 84 was submitted to the
City of Orono on September 27, 1991, in exchange for a Discharge
of Notice of Lis Pendens .
Please review and execute the enclosed Stipulation and
return it to me . I will ensure tha� tre do�ument is filed with
Hennepin County District Court for this matter .
Very truly yours ,
,��. -PQ.Le �`�I�-�
Suesan Pace-Shapiro
Deputy City Attorney
for the City of Orono
SPS/mah
cc: Ron Moorse
Thomas J. Barrett
1178NEH
STATE OF MINNESOTA DISTRICT COURT
COUNTY OF HENNEPIN FOURTH JUDICIAL DISTRICT
CASE TYPE: HAZARDOUS BUILDING
IN THE MATTER OF A HAZARDOUS ) Court Case No. 89-5885
BUILDING, being a certain )
dwelling known as 2180 Prospect )
Avenue, Orono, Minnesota, and )
legally described in Hennepin ) STIPULATION OF DISMISSAL
County as part of the Northeast )
Quarter of the Southwest Quarter )
of Section 10, Township 117, )
Range 23 , Hennepin County, )
Minnesota, as filed in the )
Office of the ounty Recorder, )
Hennepin Count , Minnesota. )
Petitioner, City of Orono ("City" ) and Respondent, the
Estate of Fred Curtis ( "Estate") , having settled their claims,
hereby stipulate to a dismissal of the hazardous building action
for property at 2180 Prospect Avenue, which is legally described
as :
All that part of the Northeast 1/4 of the
South�est 1/4 of Section 10, Township 117,
Range 23 described as follows : Beginning
at a point on the West line of the
Northeast 1/4 of the Southwest 1/4 of said
Section 10, 515 . 625 feet North of the
Southwest corner of said Northeast 1/4 of
the S uthwest 1/4; thence North 130 feet;
thenc East 208 feet; thence South 130
feet; thence West 208 feet to the point of
begin ing.
�
. '
The City and the Estate agree to dismiss the
above-captioned matter with prejudice and without further costs
or disbursements consistent with this stipulation.
DATED: POPHAM, HAIK, SCHNOBRICH & KAUFMAN, LTD.
� By:
Suesan Pace-Shapiro, Reg. No. 199345
3300 Piper Jaffray Tower
222 South Ninth Street
Minneapolis, Minnesota 55402
Telephone: �612) 333-4800
i
I ATTORNEY FOR PETITIONERS
I
DATED: ROBERT M. PEARSON LAW OFFICE
By:
Robert M. Pearson Reg . No.
13005 Main Street
Rogers, Minnesota 55374
Telephone: (612) 428-2297
ATTORNEY FOR RESPONDENT
1 192NEH
�
-2-
� -
POPHAM HAIK
2400ONETABORCENTEF SCHNOBRICH & KAUFMAN, LTD. 3300PIPERJAFFRAVTOWER
1200 SEVENTEENTH STREET 222 SOUTH NINTM STREET
DENVER,COLORAD080202 MINNEAPOLIS,MINNESOTA55402
TELEPHOr+E 303-893-1200 TELEVNONE 612-333-4800
TE�ECOPiER303-893-2194 MINNEAPOLIS, MINNESOTA TE�ecoPiEn612-334-2713
4100 CENTRUST FINANCIAL CENTER 13001 STREET,N.W.
IOO S.E.SECONO STREET SUITE 500 EAST
MIAM1,FLORIDA 33131 yraG.�ON,D.C.2000$
NANCY E. HUSNIK GTMO��
Te�ePnoHe 305-530-0050 QRQ�1"Q Te�EPHone 202-962-8700
DIRECT DIA�(612)334-2549 1—-- -- �
Te�ecoPiea 305-530-0055 rl ��[ L�i�. � Te�ecoPiEa 202-962-8799
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September 19 , 1991
��E�� 2 3 �.991
Ms . Renee Fjeld
Equity Title
17113 Minnetonka Blvd .
Minnetonka, MN 55345
Re: Property at 2180 Prospect Avenue, Orono, Minnesota
Seller : Estate of Fred Curtis
Buyer : Mike Hilbelink
Dear Renee :
This office represents the City of Orono .
I am enclosing two copies of Orono Resolution No . 3009
passed by the Orono City Council on August 26, 1991 . I would
like you to retain one copy for your file. I am requiring your
assurance that the other copy will be given to the buyer,
Mr . Hilbelink, at the time of closing . Mr . Hilbelink' s
attention should be pointed specifically to page 2 , Item 1(A)
under the heading "Conclusions, Order and Conditions . " It must
be understood by Mr . Hilbelink that Item 1(A) conditions the
issuance of any building permit upon the �full payment of fees
owed to the City of Orono as a result of the hazardous building
action conducted against this property.
To convey your assurance that this document has been
provided to Mr . Hilbelink at time of closing, you may either
contact me by phone at the number above or send me written
assurance.
{ � r� )
Ms. Renee Fjeld
Equity Title
September 19, 1991
Page 2
Thank yqu for your assistance in this matter.
Very truly yours,
�� � -
Na icy E�� Husnik
Let�al Assistant for the
City of Orono
NEH/mah
Enclosures �
cc: Ron Moorse
Tom Kuehn
Thomas Barrett
Suesan Pace-Shapiro
t 186NEH
c �
POPHAM, HAIK, SCHNOBRICH & KAUFMAN, LTD.
3300 PIPER JAFFRAY TOWER
MINNEAPOLIS, MINNESOTA 55402
`NAYNE G. POPHAM DAVID q,JONES TELEPNONE
TIMOTMY W. KUCK JULIE FLEMING-WO�FE
RAYMOND A. FiAIK LEE E.SHEEHY
ROGER W. SGHNOBRICH ALAIN RRECON 612-333-4HOO BRVCE A.PETERSON DEBORAH A.DYSON
OENVER KAUFMAN LESLIE GILLETTE TELECOPIER RUTH A.MICKELSEN BENSON K.WHI'NEY
JANNA SEVEAANCE KATHRYN M.wA_KER
ROBERT A.MINISH MICHA�L T. NILAN 1331 612-334-2713 THOMAS G.MIELENHAUSEN `^aEORGE J.SOC!iA
ROIFE A.WORDEN THOMAS M. SIPKINS 1321 612-334-27B1 MICHAEL D.GHRISTENSON SHANE R. KELLcY
G. MARC wHITEHEAD ROBERT C.MOILANEN J. MICHAEL SCHWARTZ MARK F.TEN EYCK
BRUCE D.WILLIS THOMA F. NELSON �311 612-334-2503
� JEFFREY P.CAIRNS DUANE R. NOECKER
G. ROBERT JOHNSON THOMA J. RADIO ELLEN L.MAAS DEE ROWE
GARY R. MACOMBER DAVID .HASHMAII • LEWIS J. ROTMAN GARV P.GENGELII
ROBERT S. BURK KATHL EN M. MARTIN SU�TE 2400 TODD M.JOHNSON JOHN M.BAKER
HUGH v P�UNKETT,I11 JOHN .CHILDS 1200 SEVENTEENTH STREET LOUIS P.SMITH KAREN M. HANSEN
FREDERICK C.BROWN DOUGL 5 P.SEATON BRUCE H. LITTLE SVESAN VACE-SHAPIRO
TNOMAS K.BERG THOMA E.5.>NNER DENVER� COLORADO 80202 MARK F. PALMA STEVEN M. PHIL�IPS
JAMES B.ORUCK RICHAWD A.KAP�AN TELEPHONE 303-B93-1200 RUSSELL 5. PONESSA �INDA 5.FRIEDNER
JEFFREY 5. HALPERN BRUGE�'�,8.MCPNEETERS TE�ECOPIER 303-693-2194 BRYAN L.CRAWFORD ANOREW D. PARKER
BRUCE D. MALKERSON SCOTT �.RICHTER MATTHEW E.DAMON JOY M.WALDERA
JAMES R.STEILEN PAUL J.�LINSTROTH
SU�TE 300 SOUTH .�ONN W. PROVO PATRICIA A.O'LcARY
JAMES 6. LOCKNART SCOTT A.SMITH .JILL I. FRIEDERS KAREN R.COLE
ALLEN W. FIINDERAKER BRIAN N.JOMNSON iB00 M STREET,N.W.
PAUL B.JONES
CLIFFORD M.GREENE BRADLEY A,PULLER WASHINGTON, D. C. 20036 WILLIAM D.HITTLER
D. wILLIAM KAUFMAN DONALO M. LEWiS TELEPHONE 202-828-5300 ELLEN SUE PARKER
PAUL H.TIETZ KENNETH RO55• TELECOPIER 202-62B-5316 GREGORV G.BROOKER oF COur�SEL
MICHAEL O. FREEMAN DAVID R.STRANO BRIAN W.OHM FRED L.MORRISON
HOWARD SAM MYERS,�II SCOTT K_GOLDSMITM DIRECT DIAL NUMBER GREGORY G.SCOTT JUDITH YOUNGER
IARRY D. ESPEL GIRAR�P.MILLER � ROSANNE G.ZAIDENWEBER
JANIE 5.MAYERON ELIZAB�TH A.THOMPSON CECILIA M.MICHEL
TFiOMAS J. BARRETT KEITH J. HALLELAND ( 612> 334-2549 ROBERT C.CASTLE
JAMES A.PAYNE MARK B.PETERSON TNERESE M.HANKEI .owirrcy�wu�icowr.u�ucw�ssoun�
INCLUDING THE FORMER LAW FIRM OF HAI.PERN 6 DRUCK
October 22, 1990
Equity Title
17113 Minnetonka Boulevard
Minnetonka, Minnesota 55345 =
Attention: Lori
RE: Closing of Property at 2180 Prospect Avenue, Orono,
Minnesota
Dear Lori :
It is my understanding that you are the closer on the sale
of the above property. Per our conversation on October 15, 1990,
you indicated you would need a Discharge Notice of Lis Pendens to
remove the Lis Pendens placed within the Seller ' s title due to a
hazardous building action. As per our conversation, I am sending
you a copy of the proposed Discharge.
You informed me that fees owing to the City due to the
hazardous building action will be deducted from the closing
proceeds when the closing of the sale of the property takes
place. Once the City receives a check for the outstanding fees
it will surrender an original, executed Discharge. I believe the
purchaser, Michael Hilbelink, has been in touch with Ms. Jeanne
Mabusth at the City of Orono and understands the arrangement.
Please contact me when you know the exact date.,of
closing. I will then process the Discharge so a signed and dated
original can be sent to Orono City Hall in time for the closing .
� •
Equity Title
October 22, 1990
Page 2
It is my under tanding that you will file the Discharge �otice of
Lis Pendens . will need the filing data, including document
number once yo receive that from the County.
Should �ou have any questions, please contact me.
Very truly your ,
��
r,
N cy E Husnik
L gal ssistant
cc: Jeanne Mabusth
Thomas Barrett
65ZNEH
:
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:'art 1��,,-(�cmplet� . .. - . C OZ'IIl i�v O. O!—!Yi �.v� j� �ninne�f.3 ' r n� _ •inK- �d�+e(h�i',-�r n.
Q
Sta�e of lYlinn�sota, `JJ. District �ourt,
County of h�NNEPIN Fourth Judicial District
In the Matter of a I�-azardous BuildinQ at Court File
2180 Prospect Avenu� Orono, Minnesota No. 89-5885
vs. Plaintiff
Defendant—�
KNOW ALL BY THE E PRESENTS, That the undersigned Suesan Pace-Shapiro, Assistant
Cit Attorne for th Cit of Orono Minnesota
do e S hereby certify that a ertain Notice of Lis Pendens,in the above entitled action,which has been pending in
the above named Court, an which affected, involved and brought in question the real estate, situate in the
County of Hennepin and State of Minnesota, described as follows, to-wit:
All that part of the Nprtheast 1/4 of the Southwest 1/4 of Section 10, Township 117,
Range 23 described as follows: Beginning at a point on the West line of the Northeast 1/4
of the Southwest 1/4 of said Section 10, 515.625 feet North of the Southwest corner of
said Northeast 1/4 of the Southwest 1/4; thence North 130 feet; thence East 208 feet;
thence South 130 feet; thence West 208 feet to point of beginning.
and which was filed for record in the office of the County Recorder of said County of Hennepin
on the 13th r]ay of Sentember , 19�2, and recorded in Book of
on page as Doc No. 5573700 is hereby discharged and
said action has been dismissed so far as it pertains to the above described real property.And the County Recorder
of said County is hereby authorized and directed to discharge the same upor.the record thereof,according to the
statute in such case made and provided.
IN TES�,TIMONY WHEREOF,The undersigned h�_�_hereunto set her hand—this
"�''�' �day of September , 1g91 ,
,,�l:�Ic�u, 1�2c2.-�=at�
3uesan �- iSTapiro
State of Minnesota, l� J�.
County of Henne in
On this ��r` day of SentPmhar , 19�L, before me,
a notary public within and for said County, personally appeared
Suesan Pace-Shapiro, �Assistant Citv Attornev for the Citv of Orono. MinneGota
to me known to be the person�described in, and who executed the foregoing instrument, on behalf
of the City _�nd acknowledged that�he—executed
� fSee Note1
the same as the free act and deed of the Git� .
ISee Note)
NnTARIAI,ti9'AMP l�lt tiF:AL�(�H O'PHF.R TITI.F:ON RANKi
M
���.�1"'��A
� ou�oT�cou�m► �'y�i'��,��,, ������
����'�fl�11,1995 til(;N.4�I'ltHh:Oh'NOTAKY PIJRLI('ON(YfHF:R�)FFI('IAI.
NOTF.:The hlank lines marked"tiee Note"nre for uae when the instrument is executed by an uttornry.
I�oc. No.
+;�'.•. �:,+r-y� . a
DISCHARGE OF NOTICE ` ��"�� ', '
:
OF LIS PENDENS ; '��.�- :�� ��
Partial or Complete '� -� �� '
� �:�� `
� x
.. �
; .,
VF '
Office of County Recorder
State of Minnesota, l
County of )
I hereby certify that the within Instru-
ment was filed in this office for record on
the da,y of
--,
19—, �t o'clock M.,
and was duly recorded in Book
of , page or
� Copied � Microfilmed
and was duly recorded as instrument
No.
County Recorder.
By Deputy.
, ^
�
EXHIBIT A
:
All that part of the Northeast 1/4 of the Southwest
1/4 of Section 10 , Township 117 , Range 23 described
as follows : Beginning at a point on the West line
of the Northeast 1/4 of the Southwest 1/4 of said
Section 10 , 515 . 625 feet North of the Southwest
corner of said Northeast 1/4 of the Southwest 1/4 ;
thence Nor�n 130 feet ; thence East 208 feet ; thence
South 130 feet ; thence West 208 feet to point of
beginning .
♦ �r"''
P �� 1� �� .� �� H .� Ih
2�OOOnETaBOAGENTE.R SCHNCSRtCH & KAUFMAM1 . LTC. 33cJOPiFEHJnrr�HnvTc>wE=
I ZOO SE�ENTEENTM STREET 222 S�UTti N�NTn STREET
DENVER,COLORADO 80202 Mihrvt.APO�iS.M�NNESOTn GSSOL
TE�EPHOHfi 303�893-I200 TE�Eanor�E 612-333-4800
TE�ECoaiER303-B93-2194 MINNEAPOLIS, MINNESOTA TE�ECOPiER612-334-2713
�
41OOGENTRUSTFINANCIAICENTER ,
1300I STREET,N.W.
100 S.E-SECOND STREET � SUiTE 500 EAST.
M�nr�i,F�onion 33131 WASMINGiON,D.C.ZOOOS
TE�EPno�+E305-530-0050 NANGY E. HUSNIK TELEPMONE2O2-9G2-B7OO
DIREGT DIAL (612)334-2549
TE��COPiER 305-530-0055 TE�ECoviER 202-962-8799
Se�tember 4 , 1991
Equity Title
17113 Minnetonka Blvd.
Minnetonka, MN 55345
Attn: Lynette Knickerbocker
RE: Closing on Property at 2180 Prospect Avenue,
Orono, Minnesota
�
Dear Lynette :
I received a message on Tuesday, September 3 , 1991
sometime after 4 : 00 from Robert Pearson concerning the above
referenced property. Mr . Pearson indicated he was in a closing
and wanted me to return his call .
When I contacted Equity Title, I spoke to you who
indicated that the closing had taken place and that money for
fees, incurred in a hazardous building action on the above
property, and owed to the City to Orono, had been deducted at
the closing . It was expected that a Discharge to our Notice of
Lis Pendens was to be prepared by our office once the City
received a check.
I am enclosing a copy of a letter I sent to Lori on
October 22, 1990,. This letter reflects the conversation we had
concerning a prolposed closing for the above property. In the
letter, I requested that Lori inform me when she knew the exact
date of closing so that the process for discerning the fees and
executing the Discharge could be arranged. I received no such
call and the only notice of a closing was Mr . Pearson' s call at
approximately 5 : �J0 late on September 3 , 1991.
� ti
!
Equity Title
September 4 , 1991
Page 2
At this point , I am not aware of the fee amount you used
at time of closing . However, I am aware that since the date of
our conversation of October 15, 1990, the City has incurred
further legal fees on this property, in the amount of $527 . 00 .
The total amount owing to the City of Orono is $7 , 353 . 00 . Until
the City receiv�s a check in the amount of $7, 353 . 00, the City
will not be in a position to release a Discharge Notice of Lis
Pendens for the property.
Please contact me if you need further information.
Very truly yours ,
Nancy E. Husnik
Legal Assistant
NEH/mah
1172NEH
�.
cc : Thomas J. Barrett