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STATE OF MINNESOTA <br />COUNTY OF RAMSEY <br />CASE TYPE: PERSONAL INJURY /PROPERTY DAMAGE <br />DISTRICT COURT <br />SECOND JUDICIAL DISTRICT <br />City of Little Canada, <br />v. <br />Doris L. Klein, <br />Plaintiff, ANSWER AND <br />COUNTERCLAIM <br />Defendant. File No. C2 -92 -6559 <br />Comes now the Defendant, Doris L. Klein, answers as follows: <br />1. Defendant admits that the subject building is in a <br />hazardous condition and needs to be razed; <br />2. Defendant asks this Court to order the razing of the <br />subject building, exclusive of the foundation thereof; <br />3. Defendant asks the Court to order the Plaintiff to <br />secure the subject property upon completion of the razing; <br />4. Defendant asks the Court to order that the Defendant be <br />allowed to reconstruct a residential dwelling on the subject <br />property, notwithstanding any regulations, zoning or otherwise, <br />to the contrary; <br />COUNTERCLAIM <br />INVERSE CONDEMNATION <br />5. Defendant asserts that in the event the Plaintiff, City <br />of Little Canada, refuses to issue a permit or otherwise refuses <br />to allow the Defendant to reconstruct her residence, that the <br />Plaintiff shall be found to have taken the property, and thus be <br />Page 5 <br />