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<br />set forth below, Clear Channel is entitled to summary judgment declaring that the LED face <br /> <br />is lawful and enjoining the City from requiring the LED face to be replaced. <br /> <br />STATEMENT OF ISSUES <br /> <br />I. Was Clear Channel's sign permit application approved by operation ofIaw? <br /> <br />2. Was Clear Channel's replacement of the sign face with a new LED sign face a <br /> <br />pennissible "improvement" within the meaning of Minn. Stat. 9462.357, subd. Ie? <br /> <br />2. Can the City require Clear Channel to remove the LED sign face on the basis <br /> <br />of lighting restrictions set forth in the municipal sign ordinance? <br /> <br />DOCUMENTS COMPRISING THE RECORD <br /> <br />A. <br /> <br />Affidavit of Michael C. Soules ("Soules Aff.") and the exhibits attached <br /> <br />'I <br />, <br /> <br />thereto: <br /> <br />Exhibit A: Transcript of September 1 0, 2007, Arden Hills City Council <br />meeting <br /> <br />Exhibit B: Arden Hills Sign Code (adopted June 26,2006) <br /> <br />Exhibit C: Transcript of Minnesota House floor session on May 12,2004, <br />and accompanying affidavit of Cynthia R Nelson <br /> <br />Exhibit D: Legislative record for SF2274, which amended Minn. Stat. 9 <br />462.357, subd. Ie <br /> <br />Exhibit E: Transcript of a hearing of the Minnesota House Local Govermnent <br />and Metropolitan Affairs Committee on February 17,2004, and accompanying <br />affidavit of Lori R Peterson <br /> <br />Exhibit F: Defendant City of Arden Hills' Answers to Plaintiff's First <br />Interrogatories, dated April 10, 2007 <br /> <br />Exhibit G: State v. Steele, No. A05-2254, 2007 WL 46054 (Minn. App. Jan. <br />9, 2007) <br /> <br />Exhibit H: Memorandum by James Lehnhoff, Arden Hills City Planner, <br />dated September 10, 2007 <br /> <br />2 <br />