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#12 - Landucci Twinhomes Preliminary Plat and PUD
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#12 - Landucci Twinhomes Preliminary Plat and PUD
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9/29/2025 1:24:12 PM
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Mr. Nathan Landucci <br />February 26, 2023 <br /> <br /> <br /> Unless and until you provide Wildflower with written confirmation of your compliance <br />with the foregoing demands, our client will consider pursuit of all available remedies against <br />your activities, which remedies are expressly stated to include taking appropriate action to <br />protect Wildflower's rights in a court of law and seeking (i) injunctive relief, (ii) the various <br />forms of financial damages provided for in Minn. Stat. §333.29, and (iii) its attorneys’ fees and <br />costs. <br /> <br /> In order to ensure that the likelihood of consumer confusion is eliminated as quickly as <br />possible and to minimize the damage to Wildflower's rights, we expect to receive your written <br />confirmation of your compliance with these demands by no later than Friday, March 3. <br /> <br /> This letter is not intended, nor shall it be construed, as a full statement of all the facts and <br />circumstances relating to this matter. Nothing contained in this letter is intended as or should be <br />deemed to be a waiver or reduction of any rights, claims, defenses, or remedies that Wildflower <br />may have with respect to this matter, all of which are expressly reserved. We look forward to <br />your timely response. <br /> <br />Yours sincerely, <br /> <br /> <br /> <br /> Sean Ploen <br /> <br /> <br />cc: Board of Directors, Wildflower at Lake Elmo, Inc. <br /> City of Lake Elmo City Planner <br /> City of Lake Elmo City Council <br /> <br /> <br />Enclosure – trademark registration certificate
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