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STATE OF MINNESOTA DISTRICT COURT <br />COUNTY OF RAMSEY SECOND JUDICIAL DISTRICT <br />FLEUR ROYALE PARTNERSHIP, <br />a Minnesota general partnership, <br />vs. <br />CITY OF LITTLE CANADA, <br />Plaintiff <br />Defendant <br />COMPLAINT <br />Plaintiff, for its complaint, alleges as follows: <br />1. This proceeding is instituted to obtain a declaration. as to the <br />construction and validity of Little Canada Municipal Code Section <br />2101.050, as applied to the hereinafter stated facts, and to <br />determine and obtain a declaration of the rights and status <br />of plaintiff thereunder. <br />2. In 1979 plaintiff purchased an apartment building consisting of <br />117 apartment units at 181 Little Canada Road, in the City of <br />Little Canada, County of Ramsey, Minnesota. <br />3. On information and belief, plaintiff alleges that said apartment <br />building was constructed in approximately 1972 subsequent to <br />receiving all necessary approvals from the City of Little Canada. <br />Plaintiff alleges that said apartment units were occupied <br />by tenants shortly after construction was completed. <br />4. On information and belief, plaintiff alleges that the City <br />of Little Canada learned of plaintiff's intent to convert <br />said apartment building to condominiums in late 1979. <br />5. At a meeting of the City Council of Little Canada on November 28, <br />1979, the following resolution was adopted: <br />RESOLUTION NO. 79 -11 -537 - Amending Chapter 2101.050 <br />of the Little Canada Code to reflect that the park <br />charges for a subdivision for condominium conversion <br />1. r; <br />