05-25-1977 Council Agenda - Laserfiche WebLink

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JAMES R. BELL E. MARTIN STAPLETON MARK M. NOLAN 04 9avizeoLn, A ATTORNEYS AT LAW 2600 AMERICAN NATIONAL BANK BUILDINO 101 EAST FIFTH STREET SAINT PAUL, MINNESOTA 66101 TELEPHONE (612) 227 -6661 May 23, 1977 Mrs. Eleanor Rydel 78 West Demont St. Paul, Minnesota 55117 RE: Our File No. 7848 RICHARD M. VOGEL ROGER R. LENZSIEIER Dear Mrs. Rydel: This letter will advise you that our firm has reviewed the material which you have supplied to us with regard to a possible judicial review of the action of the City Council should it authorize the present proposed expansion of the trailer court. Ordinarily the scope of judicial review of the Council, should it approve such an expansion, would be very limited. However, our re- view of the documents which you have supplied us indicates that there is a significant difference in your particular case which may provide you additional legal remedies not available to most homeowners. By this I mean that we have reviewed the notes of the Council on May 15, 1972 where it was resolved that a buffer zone was the condition upon which the last expansion was granted to the trailer park. It is_fur- ther our understanding that in reliance of the establishment of this buffer zone you have put significant improvements into your home as late as 1976. If I have correctly recited the facts, then doctrines of equitable estoppel may very likely be available to you in the judicial review of your case, since both the trailer court and the City Council were aware of the establishment of a buffer zone and you have relied on that buffer zone in the additional investment you have placed in your home after the establishment of the buffer zone. We further under- stand that after the establishment of the buffer zone you would have had an opportunity to .sell the property prior to placing this addi- tional investment in the house, but again relied on the establishment of the buffer zone to protect your property value and additional in- vestment. Page -5- MAY 25 1911 CITY o' LITTLE CANADA).