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IVERSON REUVERS PAUL �. RE�,�$ <br />ATTORNEYS AT LAW n�c'i': 9sz.sas.�zos <br />pg� � V���aV ��{gON 1.AW.COM <br />February 7,2005 <br />Doug Gronli <br />LMCIT Claims <br />145 UniversityAvenue West <br />St. Paul. MN 55103-2044 <br />RE: Friends of Twin Lakes v. City of Roseville <br />Dear NIr. Gronli: <br />Thank you for your correspondenceregarding the City of Roseville litigation. I <br />understand the City Administratorhas requested background information on our <br />experience in land use claims and in particular, MERA claims. <br />As you know, my practice is primarily involved with the defense of municipal <br />liability claims, land use claims and civil rights lawsuits. I have been involved in <br />municipal defense litigation since 1992, following a clerkship for Minnesota <br />Supreme Court Justice Esther M. Tomljanavieh. During that time, I have <br />successfully defended cities, counties and townships in both straig�t-forward and <br />complex land use matters throughout the state. Since starting this firm in 2001, I <br />have had a number of cases involving MEpA and just finished a successful trial <br />involving a hotly contested MERA claim for Koochiching County. I am certain <br />the Koochiching County Attorney would provide a candid assessment of our <br />handling of this file on behalf of the County. <br />I am enclosing copies of the Order concerning the cross-motions for summary <br />judgment and the Findings of Fact, Conclusions of Law and Order from this case. <br />As you can see, this case involved both 1VYEPA and MERA claims stemming from <br />the County's proposed construction of a sewer system on �ac��sh Bay on Rainy <br />Lake. The Environmental Law Group represented the Plaintiffs and used MEPA <br />and MERA to attack the project on a number of levels. The MERA claim, in <br />particular, presented a unique challenge. Plaintiffs were able to avoid summary <br />judgment on the MERA claim by retaining a Harvaard-educated engineer to opine <br />our project would harm the environment. At trial, I was able to discredit him on a <br />number of his opinions. The trial resulted in a favorable outcome for the County <br />and an appeal has been filed. <br />]�l� IC. IVkRSQN <br />PAUL D. R�Uv��S <br />]EFF M. T,ALASKY <br />JASONJ. KuaoUSxeK <br />MAAK$.BRON:v <br />FAiiak]F_ WHITMOitfi <br />JASON M. kIN�LEY <br />SUSA\ M.iINDAL <br />SEFFREYA. E(',G8 <br />�VERSON REUVERS, CCC � 9321 ENSIGN t�YENl36�0UTH I�iLODMIMGTON� M� 55438 � g$2.$4$.i20a � FAX: 952.946.1501 �� ti+ww.�r=ksrwraw.c:=,„ <br />