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UNITED STATES BANKRUPTCY COURT <br /> DISTRICT OF MINNESOTA <br /> FOURTH DIVISION <br /> Chapter 11 Case <br /> In re: <br /> BKY Case No. 4-95-876 <br /> Northridge Properties, <br /> Debtor. <br /> RESPONSE OF CITY OF MOUNDSVIEW TO MOTION BY MINNESOTA HOUSING <br /> FINANCING AGENCY FOR RELIEF FROM STAY, OR IN THE <br /> ALTERNATIVE, CONVERSION OR DISMISSAL OF CASE <br /> The City of Moundsview, by and through its undersigned counsel, hereby serves and files <br /> its Response to the Motion of the Minnesota Housing Finance Agency ("MHFA") in which the <br /> MHFA seeks a modification of the automatic stay in this case, or in the alternative, a dismissal <br /> or conversion of this case. <br /> The City of Moundsview is owed approximately $56,000 on a past due water utility bill <br /> which has been delinquent for a considerable period of time. The City maintains that this water <br /> utility bill is a lien upon the real estate project owned by the Debtor. <br /> The City of Moundsview supports the Motion of the MHFA. The City of Moundsview <br /> believes that the interests of the creditors in this case are best served by modifying the automatic <br /> stay in this case to allow the MHFA to exercise its rights and remedies with respect to the real <br /> estate project owned by the Debtor. In addition, the City of Moundsview will not support or <br /> accept any Plan of Reorganization proposed by the Debtor, unless such Plan of Reorganization <br /> pay the amount owed to the City of Moundsview, in full, immediately upon confirmation and <br /> without impairment of its claim. <br /> HOLMES & GRAVEN <br /> Dated: By <br /> James Thomson <br /> Attorneys for the City of Moundsview <br /> 470 Pillsbury Center <br /> Minneapolis, MN 55402 15140i <br />