Wednesday, August 27, 2008

Frank Steinhauser RICO update_Civ04-2632

As on file at www.ademocracy.blogspot.com
Saint Paul RICO UPDATE/ PLAINTIFFS’ JOINT MEMORANDUM OF LAW IN OPPOSITION TO SUMMARY JUDGMENT - AMENDED"

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Blogger Bob said...

Hi All,

New here? To bring yourself up to speed on this issue please read the RICO lawsuits against the City of Saint Paul. There is a link on the front page to the right of the screen. Scroll down until you see the "Scales of Justice".

The plaintiffs opposition to summary judgement is 78 pages in length. I will post it in sections over several days under new topic post.

There is over 2000 exhibits. SO, we have a lot to discuss.



UNITED STATES DISTRICT COURT
DISTRICT OF MINNESOTA
Frank J. Steinhauser, III, et. al., Civil No. 04-2632
JNE/SRN
Plaintiffs,
v. PLAINTIFFS’ JOINT MEMORANDUM OF LAW IN OPPOSITION TO SUMMARY JUDGMENT - AMENDED
City of St. Paul, et. al.,
Defendants.
Sandra Harrilal, et. al., Civil No. 05-461
JNE/SRN
Plaintiffs,
v.
Steve Magner, et. al.,
Defendants.
Thomas J. Gallagher, et. al., Civil No. 05-1348
JNE/SRN
Plaintiffs,
v.
Steve Magner, et. al.,
Defendants.
Case 0:05-cv-00461-JNE-SRN Document 237 Filed 08/25/2008 Page 1 of 78
2
INTRODUCTION
Plaintiffs will show the Court that summary judgment as requested by Defendants is improper as there are genuine issues of material fact present in every claim presented in the Complaint.
Prior the Court considering Defendants’ motion for summary judgment, Plaintiffs request that the Court consider the facts and issues raised by Plaintiffs in their spoliation motions, and once again consider Plaintiffs’ renewed request that the Court deny Defendants’ motion for summary judgment due to destruction of relevant evidence related to defenses raised by Defendants including immunities, and to Plaintiffs’ claims. Plaintiffs’ submit that there is now even more evidence before the Court of Defendants’ non-disclosures and/or destruction of evidence relevant to claims and defenses herein, including Defendants’ failures to disclose federally mandated “analysis of impediments” (AI) to affordable housing related to Defendants’ affirmative duty to further fair housing (AFFH). In over four years of discovery herein, Defendants have failed to produce, and Plaintiffs have been unable to discover, any evidence that Defendants ever conducted an AI for disclosure to the U.S. Department of Housing and Urban Development (HUD) and the public related to whether the “protected class” was adversely impacted by the City’s application of its “heightened code enforcement standard” and illegal policy of removing “grandfathering rights” under the Minnesota State Building Code through “Code Compliance” inspections and certifications applied to older inner-city housing stock disproportionate occupied by “protected class” members. This issue is not to be taken lightly, as falsification of AFFH certifications in return for hundreds of
Case 0:05-cv-00461-JNE-SRN Document 237 Filed 08/25/2008 Page 2 of 78
3
millions of dollars in federal funding and spoliation of documents related thereto through destruction of internal documents, including e-data and e-mail communications, have serious implications. Defendants spoliation of written communications, including e-mails and other e-data for the years prior to 2005, has left Plaintiffs, HUD and the public without the key evidence HUD required the City to maintain related to the Defendants’ Fair Housing certifications and obligations. HUD regulations require the City to conduct a full and fair analysis of impediments to fair housing in the City, to identify those impediments, including those based on the City’s legislative code, rules, procedures and practices related to fair housing and “protected classes,” its illegal demands to the private market landlords in the City to meet expensive “code compliance” inspections and its creation of other barriers to fair housing. The City’s illegal “Code Compliance” requirements subverting grandfathering protections for older buildings in violation of the State Building Code, brings into question whether the City falsified its certifications to HUD through material non-disclosures.
INTRODUCTION OF PLAINTIFF RENTAL PROPERTY OWNERS
Plaintiffs are or were landlords providing housing primarily to low-income, “protected class” tenants in the City and at various times housing under the Federal Section 8 funded program. Plaintiffs owned and managed older rental properties located in the inner-city neighborhoods where older housing stock was common, where poverty was persistent, and where people of color had a critical need for safe and decent affordable housing. See generally Affs. of Plaintiffs attached as Exs. 70-79 to 2nd Engel Aff., and Exs. 140-144 to 2nd ShoemakerAff.
Case 0:05-cv-00461-JNE-SRN Document 237 Filed 08/25/2008 Page 3 of 78

8:09 PM

My Documents Scribd

Pdf_16x16 Steinhauser v.CitySt.Paul_SumJud29Jul08 17

Freedom-4You: Steinhauser et al v. City St.Paul_Magner et al Civ 05-461 ...

24 days ago 14 Published Edit Delete Share Preview

Pdf_16x16 SteinHauser v.CitySt.Paul_Magner et al CV-04-2632

2n Amend Complaint 113 pages

26 days ago 30 Published Edit Delete Share Preview

Pdf_16x16 Steinhauser et al v. City St.Paul Civ04-2632

Landlords Anti Trust, RICO lawsuits v. City St. Paul,MN Files from ECF D...

27 days ago 19 Published Edit Delete Share Preview

Pdf_16x16 Raven Property Managment v. City of St. Paul

Federal Cases v. City St. Paul, Published ECF, Pacer Accts

Posted by Sharon 4Anderson at 8:20 AM 0 comments

Wednesday, October 24, 2007

AD-2007

Wednesday, October 17, 2007

Saint Paul/ RACKETEERING Law suits exhaust resources of city attorneys office.

Please click onto the TITLE of this post for the video.

posted by Bob at Wednesday, October 17, 2007 21 comments links to this post

Saturday, October 13, 2007

Video Vigilante Strikes Again

Please click onto the TITLE of this post for the video
.

posted by Bob at Saturday, October 13, 2007 19 comments links to this post

Thursday, October 11, 2007

Another city worker caught with his hand in the cookie jar.

Please click onto the COMMENTS for the story.

posted by Bob at Thursday, October 11, 2007 44 comments links to this post

St. Paul's House of Cards by Nancy Lazaryan.

Please click onto the COMMENTS for the story.

posted by Bob at Thursday, October 11, 2007 34 comments links to this post

Wednesday, October 10, 2007

Saint Paul City Council Election

Please click onto the TITLE of this post for the story.

posted by Bob at Wednesday, October 10, 2007 7 comments links to this post

Tuesday, October 09, 2007

Milwaukee/ Henningsen indicted on 5 federal counts

Please click onto the COMMENTS for the story.

posted by Bob at Tuesday, October 09, 2007 9 comments links to this post

Monday, October 08, 2007

FREE DOG



My name is Charlie. I am 2 years old. I'm not like other dogs, I am special!

I am potty trained and flush. I have a preference for people food, and I always lick my plate clean. I don't like kids, mailmen, dog catchers and cold weather.

Need love and affection, my Dad abandoned me.

posted by Bob at Monday, October 08, 2007 8 comments links to this post

Suburbs get tough with single-family rentals

Please click onto the COMMENTS for the story.

posted by Bob at Monday, October 08, 2007 2 comments links to this post

FEDERAL GRAND JURY CHARGES CURRENT AND FORMER PUBLIC OFFICIALS AND THEIR ASSOCIATES IN BRIBERY AND EXTORTION SCHEME

Please click onto the COMMENTS for the story.

posted by Bob at Monday, October 08, 2007 9 comments links to this post

Saturday, October 06, 2007

Man And Boy Stabbed With Sickle

Please click onto the COMMENTS for the post.

posted by Bob at Saturday, October 06, 2007 8 comments links to this post

Crime Strategy/ Thugs out for a stroll.

videovideo

Click twice to see video.

posted by Bob at Saturday, October 06, 2007 3 comments links to this post

Tuesday, October 02, 2007

DIRTY DEEDS DONE CHEAP!

Please click onto the TITLE for the post.

posted by Bob at Tuesday, October 02, 2007 36 comments links to this post

Monday, October 01, 2007

October/ Domestic Abuse Awareness Month Memorial Slide Show

Click onto the TITLE of this post for a domestic violence memorial slide show. Click onto the COMMENTS for a message from Patty Bruce.

posted by Bob at Monday, October 01, 2007 4 comments links to this post

Saturday, September 29, 2007

UNBELIEVEABLE !

Please click onto the TITLE of this post for the story. Nancy L. sent me this.

posted by Bob at Saturday, September 29, 2007 9 comments links to this post

Friday, September 28, 2007

City threatens to revoke rental license

Please click onto the COMMENTS for the story.

posted by Bob at Friday, September 28, 2007 12 comments links to this post

Old computers dumped in lake & other metro toxic waste contaminated sites

Please click onto the COMMENTS for the story.

posted by Bob at Friday, September 28, 2007 16 comments links to this post

Sunday, September 23, 2007

Is this really affordable housing!

Please click onto the COMMENTS for the story.

posted by Bob at Sunday, September 23, 2007 114 comments links to this post

Video/ We won't Back down!

videovideo

Click twice to view

posted by Bob at Sunday, September 23, 2007 30 comments links to this post

Friday, September 21, 2007

Should we turn our neighbors into code enforcement?

Please click onto the COMMENTS for the post.

posted by Bob at Friday, September 21, 2007 154 comments links to this post

Mike Hatch is a hero...

Please click onto the COMMENTS for the post.

posted by Bob at Friday, September 21, 2007 8 comments links to this post

Wednesday, September 19, 2007

SAINT PAUL/ Police kill man who rush them with a knife.

Please click onto the COMMENTS for the post.

posted by Bob at Wednesday, September 19, 2007 7 comments links to this post

BURNSVILLE/ Mans threats are not enough to lose housing voucher.

Please click onto the COMMENTS for the post.

posted by Bob at Wednesday, September 19, 2007 2 comments links to this post

Tuesday, September 18, 2007

Attorney General Paulose under federal investigation.

Please click onto the TITLE of this post for the story.

posted by Bob at Tuesday, September 18, 2007 17 comments links to this post

Sunday, September 16, 2007

I GOT THE VIDEO FOLKS! Here it is, Nancy Osterman telling her story of corruption against her by Saint Paul City Officials.

Click onto the TITLE of this post for the story. After you see the video, check out the web site it is uploaded to. It's GREAT!

posted by Bob at Sunday, September 16, 2007 14 comments links to this post

New Member Introduction "Troubles in our courts"

Please click onto the COMMENTS for the post.

posted by Bob at Sunday, September 16, 2007 11 comments links to this post

Thursday, September 13, 2007

Our Nancy Osterman was on the "Inside Insight" t.v. show!

Hi All,

If you are new here and looking for information on Nancy Osterman's story, please look to the top left of the page and type "Nancy Osterman" in the "search this blog box". Or type "Helgen" in the same box and you will find more information. Click onto the TITLE of this post for Nancy's blog.

posted by Bob at Thursday, September 13, 2007 44 comments links to this post

14.6% property tax increase in St. Paul for 2008

Please click onto the COMMENTS for the story.

posted by Bob at Thursday, September 13, 2007 16 comments links to this post

CORRUPT JUDGES/ The secret is out!

Please click onto the COMMENTS for the post.

posted by Bob at Thursday, September 13, 2007 3 comments links to this post

Tuesday, September 11, 2007

Incumbants win primarys/ one of the smallest turnouts in history

Please click onto the COMMENTS for the post.

posted by Bob at Tuesday, September 11, 2007 26 comments links to this post

Neighborhood Councils Not Representative of the Citizens of Saint Paul

Please click onto the COMMENTS for the post.

posted by Bob at Tuesday, September 11, 2007 48 comments links to this post

Barbara Winn Homicide/ Grand jury to hear evidence.

Please click onto the COMMENTS for the story.

posted by Bob at Tuesday, September 11, 2007 14 comments links to this post

Monday, September 10, 2007

Local Government is regulating relationships between select citizens.

Please click onto the COMMENTS for the story.

posted by Bob at Monday, September 10, 2007 6 comments links to this post

City Council Primaries On Tuesday!

Please click onto the TITLE of this post for the story.

posted by Bob at Monday, September 10, 2007 18 comments links to this post

Golden Valley"s Hidden 13.1 Million dollar tax.

Please click onto the TITLE of this post for the story.

posted by Bob at Monday, September 10, 2007 3 comments links to this post

Saturday, September 08, 2007

PUBLIC ALERT/ Beware of toe lickers!

Please click onto the COMMENTS for the story.

posted by Bob at Saturday, September 08, 2007 7 comments links to this post

Posted by Sharon 4Anderson at 3:56 PM 0 comments

Monday, July 30, 2007

Blog Locked without Cause

30July07 Candidate Ward 2 VA Widow-Whistleblower
Sharon Anderson aka Scarrella
2006 Republican Candidate Attorney General
from her Wheel Chair,
Affidavit in the event of Death by corrupt DSI Employee's Corrupt Cops et al
To the Justice Department All Agencies: FBI,
State of Minnesota, All Agencies: Governor,All Attorneys
St. Paul Voters-Citizenery-Media et al
Simple Good Faith request for intervention into the Reprehensible Conduct of City
of St. Paul, Right and Privacy of Candidate for Public Office,
COUNT I
Forgivable Loans are nothing but kick back-bribery-insider trading by council person
David Thune and others
RICO "Patterened Enterprise" by the City of St. Paul, Mayor, Police Chief,
DSI Employees, John Doe and Mary Roe
29July07 Sharon's FOIA blog is locked? without due process,
is re: submitted by e-mail for investigation, forensic evidence.
Sharon is not nor will Sharon ever SPAM, refutes the locking of her published/authored
Blogs, http://www.lawandpolitics.com/ is used for re: Sharon Anderson Do it Yourself.
has the Right to know who submitted a SPAM block against a FOIA request
Repugnant against a Freedom of Information Request Title 5.
At all times Material the Bizzare neglience of the St. Paul Police
to accept Citizens Complaint of Death Threats, Murder, Malice
Theft,Trespass and Treason is cause for Federal
Investigations
Request for investigations into the Fidicuary Taxaction without
Representation on the Simple request of Forgivable Loans and for Valid Complaints to Steal
In the event of Sharon's Death, Harm,Injury, now the locking
of Sharons FOIA,FCC Blogs
tomorrow yet another Bogus Inspection by Defendant Joel Essling
without Valid Complaints,
Sharon's Security is NOT THAT OF A
must trigger FBI INVESTIGATIONS re:
Federal Bureau of Investigation - National Press Releases FURTHER AFFIANT SAYETH NOT AT THIS TIME: Attached e-blog in its entirety for
Public Inspection, review, to prevent any further harm,injury, 4th and 5th Constutional
Amendments Violations by Public Officials.
BlogItBabe2007 Candidate profile Sharon4Anderson's Legal BlogBriefs Sharon4Anderson St.Paul City Council Ward2 SA-Blogs2007
LEGAL NOTICE: /s/Sharon4Anderson@aol.com ECF_P165913Pacersa1299 telfx: 651-776-5835: Document's are based on SEC filings, current events, interviews, press releases, and knowledge gained as financial journalists, Private Attorney Generals, Candidates for Public Office documents expressly forbids its writers from having financial interests in securities they recommend to readers, affiliated entities, employees, and agents an initial trade recommendation published on the Internet, after a direct mail publication is sent, before acting on that recommendations, and may contain errors. Investment decisions should not be based solely on theseSHARON-MN-ECF: Judges-Greylord-Libby-Guilty LUFSKY Scap129FAnokaP2697(1976) Cpl James R. Anderson USMC 11022885 Bio for Sharon Anderson , TAKING DL_AOL Journal Legal Eagle SharonAnderson 1 Journalism Ethics Blogger: 1986 Petition Jane Duchene MN Bull SharonScarrellaAndersonUSBriefs - Buzznet Sharon'sFedCases1973to2006_13pdf Anderson + Advocates http://www.sharonanderson.org/ http://www.sharon4anderson.org/
Forwarded Message:
Subj:Sharons-FOIA
Date:7/30/2007 9:53:52 A.M. Central Daylight Time
From:Sharon4Anderson
To:Sharon4Anderson
CC:EagleEyeSharon, Shewolfeagle
Sharons-FOIA
http://sharons-foia.blogspot.com/ View Blog
4 Posts, last published on Jul 25, 2007
This blog is under review due to possible Blogger Terms of Service violations, and is currently unpublished. You can view your blog's posts here in Blogger, but not make any changes.
View Blogger

Wednesday, July 25, 2007

City St.Paul Forgiveable Loans $430,000.00 RICO


APPARANTLY COMMERCE CRIMINAL VIOLATIONS similar to Enron

COUNT I MS 609.43
Sharon & Bill Fiduicary Watchdog's
QUESTIONS:

Is Nedu,LLC one and the same as NENDC,Thune's former aide Repke's non profit company? Please clarify.

If so Please note objections, triggering State and Federal Inquiry

for a 10 year period How Many forgiveable Loans? Interest Charged ?

Repke, Chuck, North East Neighborhoods Development Corporation, Chuck Repke NENDC

651.771.6955. Repke, David, Heffter Research Institute, David B. Repke, ...
www.zoominfo.com/people/level2page33259.aspx - 104k - Cached - Similar pages

651.771.6955. Repke, David, Heffter Research Institute, David B. Repke, ...
www.zoominfo.com/people/level2page33259.aspx - 104k - Cached - Similar pages

open meeting law compliance etc.

breakdown of listings of propertys,owners,decending to particulars



1. No wonder the City of St. Paul can't handle the RNC We can't budget our own Fiduciary

Contracts on the backs of the poor with all these

"Forgivable Loans published on St. Paul HRA Agenda today


" Bill Dahn states: " Forgive all parking tickets"

Sharon now beinging victimized by the Citys False Statements: charging excessive consumption

fees over $240.oo hour is Bizzare: Ratification of Assessments based on

Theft, Trespass, Treason


Stealing Cars stating Abandoned on Private property fully licensed insured, then selling

at police impound lot run by indicted Murderer aaron foster re: Barb Winn


HRASharon4Anderson@aol.com wrote: to fellow blogger Bob Johnson
what the hell is a forgivable loan???
Forgivable http://service.govdelivery.com/docs/STPAUL/STPAUL_DeptCityCouncil/STPAUL_65/STPAUL_65_20070725_en.pdf loan scroJuly 25, 2007 City Council Agenda Page 6
HOUSING AND REDEVELOPMENT AUTHORITY
OF THE CITY OF SAINT PAUL, MINNESOTA
Wednesday, July 25, 2007
2:00 . 3:00 P.M.
City Council Chambers, Third Floor
Saint Paul City Hall
Kelly Bauer, Assistant Secretary
(651) 266-6604
AGENDA
ROLL CALL
CONSENT AGENDA
1. Approval of the July 11, 2007 meeting minutes.
DISCUSSION
2. Resolution Approving and Authorizing Execution of a Memorandum of Understanding
with Nedu, LLC for the Dale Street Village on University Project, and Approval of a
$430,000 Forgivable Loan for the Acquisition of 591 University Avenue, District 7.
3. Designation of City Center Retail, LLC as Tentative Developer for the HRA-owned Seven
Corners Gateway Site, District 17
STAFF REPORT
4. Quarterly HRA Board Financial Update.3ol to end of agenda
CC:http://www.blogger.com/terms.ghttp://www.ademocracy.blogspot.com/


Posted by Sharon Anderson at 8:52 AM 0 comments

Sunday, July 22, 2007

Letter E-Blog Motion to compel Discovery
Subj:Legal FOIA- SHARON4ANDERSON@AOL.COM-FOIA
Date:7/21/2007 10:49:41 P.M. Central Daylight Time
From:Sharon4Anderson
To:chris.coleman@ci.stpaul.mn.us, tim.pawlenty@state.mn.us, attorney.general@state.mn.us, rca@co.ramsey.mn.us, askdoj@usdoj.gov, james.lackner@usdoj.gov, rs-attorney@co.anoka.mn.us, john.harrington@ci.stpaul.mn.us, bob.fletcher@co.ramsey.mn.us, bob.bierscheid@ci.stpaul.mn.us, bob.kessler@ci.stpaul.mn.us, joel.essling@ci.stpaul.mn.us, lisa.martin@ci.stpaul.mn.us, aaron.foster@ci.stpaul.mn.us, aaron@politicslaw.org, bbakst@ap.org, pcondon@ap.org, mlohn@ap.org, tim.budig@ecm-inc.com, ddavis@forumcomm.com, jcroman@kare11.com, ahart@kare11.com, klksnews@yahoo.com, ochsnews@yahoo.com, thauser@kstp.com, mfischenich@mankatofreepress.com, baverill@mndaily.com, ntibbetts@mndaily.com, lmccallum@mpr.org, tscheck@mpr.org, swente@republican-eagle.com, jayjohnson@postbulletin.com, lschumacher@stcloudtimes.com, charley.shaw@legal-ledger.com, jragsdale@pioneerpress.com, rrosario@pioneerpress.com, bsalisbury@pioneerpress.com, rstassen-berger@pioneerpress.com, jsullivan@pioneerpress.com, dbrewster@startribune.com, mbrunswick@startribune.com, pdoyle@startribune.com, ndraper@startribune.com, hopfen@startribune.com, plopez@startribune.com, lsturdevant@startribune.com, bbowring@tpt.org, mlahammer@tpt.org, EEskola, eeskola@cbs.com, pjkessler@wcco.cbs.com, randy@neighborsforrandy.org, bernie@electbernie.org, samantha@russforward4.org, webmaster@thune2007.com, info@melvincarter.org, contact@davidhaasforcitycouncil.org, helgen00005@hotmail.com, stpaulward6@gmail.com, info@pakouhang.com, trudy.moloney@ci.stpaul.mn.us, margaret.egan@ci.stpaul.mn.us, marcia.moermond@ci.stpaul.mn.us, elizabeth.davis@ci.stpaul.mn.us, kenneth.smith@ci.stpaul.mn.us, thomas.davenport@ci.stpaul.mn.us, mkib73@hotmail.com, tim@e-democracy.org, eagledahn1, velma.korbel@state.mn.us, admin.info@state.mn.us, glenn.wilson@state.mn.us, alice.seagren@state.mn.us, cal.ludeman@state.mn.us, deed.customerservice@state.mn.us, dianne.mandernach@health.state.mn.us, dianne.mandernach@state.mn.us, dli.commissioner@state.mn.us, michael.campion@state.mn.us, dan.salomone@state.mn.us, carol.molnau@state.mn.us, michael.pugliese@state.mn.us, tim.marx@state.mn.us, mhfa@state.mn.us, citizen.service@ci.stpaul.mn.us, CityofSaintPaul@govdelivery.com, jerry.ludden@ci.stpaul.mn.us, mayor@ci.stpaul.mn.us, erin.dady@ci.stpaul.mn.us, ann.mulholland@ci.stpaul.mn.us, Nancy.Homans@ci.stpaul.mn.us, Kris.Fredson@ci.stpaul.mn.us, Bob.Hume@ci.stpaul.mn.us, Chris.Rider@ci.stpaul.mn.us, Anne.Hunt@ci.stpaul.mn.us, Nick.Shuminsky@ci.stpaul.mn.us, Joe.Spencer@ci.stpaul.mn.us, Va-Megn.Thoj@ci.stpaul.mn.us, Melvin.Carter@ci.stpaul.mn.us, Vallay.Varro@ci.stpaul.mn.us, Carol.Washington@ci.stpaul.mn.us, Darlyne.Morrow@ci.stpaul.mn.us, Jean.Karpe@ci.stpaul.mn.us, Milyon.Tekle@ci.stpaul.mn.us, Sean.Johnson@ci.stpaul.mn.us, eagle@eagleforum.org, Bonnuge, matt.bostrom@ci.stpaul.mn.us, neil.melton@state.mn.us, mary.bjornberg@state.mn.us, sheryl.waddick@state.mn.us, paul.monteen@state.mn.us, peggy.strand@state.mn.us, dan.glass@state.mn.us, terry.sandbeck@state.mn.us, carol.j.hall@state.mn.us, dee.dodge@state.mn.us, starr.suggs@state.mn.us, debra.soderbeck@state.mn.us, mitch.lee@state.mn.us, bill.martinez@ci.stpaul.mn.us, mark.letexier@co.polk.mn.us, kwilkening@co.nobles.mn.us, junstad@yahoo.com, timbildsoe@visi.com, brent.richter@state.mn.us, johnp@alx.tec.mn.us, mike.ardolf@state.mn.us, tracey.a.martin@co.hennepin.mn.us, harr@csp.edu, mdohman@ci.maple-grove.mn.us, mylan.masson@minneapolis.edu, michael.young@ci.minneapolis.mn.us, john.bolduc@co.crow-wing.mn.us, diverson@pioneerpress.com, aharrington@pioneerpress.com, dbeal@pioneerpress.com, jbjorhus@pioneerpress.com, dfondler@pioneerpress.com, jforster@pioneerpress.com, mhopp@pioneerpress.com, khubbard@pioneerpress.com, rhubbard@pioneerpress.com, sjean@pioneerpress.com, jkrocheski@pioneerpress.com, lsuzukamo@pioneerpress.com, twebb@pioneerpress.com, janice.rettman@co.ramsey.mn.us, chiefclerk@co.ramsey.mn.us, jim.mcdonough@co.ramsey.mn.us, 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dave.schuler@ci.stpaul.mn.us, steve.gleason@ci.stpaul.mn.us, jim.graupmann@ci.stpaul.mn.us, waterinquiries@ci.stpaul.mn.us, russell.anderson@courts.state.mn.us, fred.grittner@courts.state.mn.us, alan.page@courts.state.mn.us, paul.anderson@courts.state.mn.us, helen.meyer@courts.state.mn.us, sam.hanson@courts.state.mn.us, g.barry.anderson@courts.state.mn.us, edward.toussaint@courts.state.mn.us, harriet.lansing@courts.state.mn.us, r.a.jim.randall@courts.state.mn.us, thomas.kalitowski@courts.state.mn.us, robert.schumacher@courts.state.mn.us, roger.klaphake@courts.state.mn.us, randolph peterson@courts.state.mn.us, james.harten@courts.state.mn.us, bruce .d.willis@courts.state.mn.us, gordon.schumaker@courts.state.mn.us, jill.flaskamp.halbrooks@courts.state.mn.us, terri.j.stoneburner@courts.state.mn.us, david.minge@courts.state.mn.us, natalie.e.hudson@courts.state.mn.us, wilhelmina.m.wright@courts.state.mn.us, christopher.j.dietzen@courts.state.mn.us
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Barbara Winn Murder aaron foster - Google Search
BlogItBabe2007
http://www.blogger.com/terms.g Candidate profile Sharon4Anderson's Legal BlogBriefs Sharon4Anderson St.Paul City Council Ward2 SA-Blogs2007
LEGAL NOTICE: /s/Sharon4Anderson@aol.com ECF_P165913Pacersa1299 telfx: 651-776-5835: Document's are based on SEC filings, current events, interviews, press releases, and knowledge gained as financial journalists, Private Attorney Generals, Candidates for Public Office documents expressly forbids its writers from having financial interests in securities they recommend to readers, affiliated entities, employees, and agents an initial trade recommendation published on the Internet, after a direct mail publication is sent, before acting on that recommendations, and may contain errors. Investment decisions should not be based solely on theseSHARON-MN-ECF: Judges-Greylord-Libby-Guilty LUFSKY Scap129FAnokaP2697(1976) Cpl James R. Anderson USMC 11022885 Bio for Sharon Anderson , TAKING DL_AOL Journal Legal Eagle SharonAnderson 1 Journalism Ethics Blogger: 1986 Petition Jane Duchene MN Bull SharonScarrellaAndersonUSBriefs - Buzznet Sharon'sFedCases1973to2006_13pdf Anderson + Advocates www.sharonanderson.org www.sharon4anderson.org

Posted by Sharon Anderson at 1:53 PM 0 comments

Saturday, July 21, 2007

Chris Coleman's Complicity FOIA

http://3.bp.blogspot.com/_p8sCq3UK2t4/RqLFwvbANYI/AAAAAAAABS0/ntOtVaGMlRo/s1600-h/697SurFiles07+005.jpg 5Jul07AgedMin Sharon4Council: Indict MS609.43-Chris Coleman

Posted by Sharon Anderson at 6:41 PM 0 comments

Monday, July 16, 2007

City St.Paul Deny Title 5 FOIA

Subj:Re: Complaints on 697 Surrey FOIA DEMAND DENIED BY DSI BOB KESSLER
Date:7/16/2007 2:43:43 P.M. Central Daylight Time
From:Sharon4Anderson
To:Robert.Humphrey@ci.stpaul.mn.us, mayor@ci.stpaul.mn.us, bob.kessler@ci.stpaul.mn.us, ron.guilfoile@ci.stpaul.mn.us, russell.anderson@courts.state.mn.us, fred.grittner@courts.state.mn.us, alan.page@courts.state.mn.us, paul.anderson@courts.state.mn.us, helen.meyer@courts.state.mn.us, sam.hanson@courts.state.mn.us, g.barry.anderson@courts.state.mn.us, edward.toussaint@courts.state.mn.us, harriet.lansing@courts.state.mn.us, r.a.jim.randall@courts.state.mn.us, thomas.kalitowski@courts.state.mn.us, robert.schumacher@courts.state.mn.us, roger.klaphake@courts.state.mn.us, mailto:randolph, james.harten@courts.state.mn.us, mailto:bruce, gordon.schumaker@courts.state.mn.us, jill.flaskamp.halbrooks@courts.state.mn.us, terri.j.stoneburner@courts.state.mn.us, david.minge@courts.state.mn.us, natalie.e.hudson@courts.state.mn.us, wilhelmina.m.wright@courts.state.mn.us, christopher.j.dietzen@courts.state.mn.us, bbakst@ap.org, pcondon@ap.org, mlohn@ap.org, tim.budig@ecm-inc.com, ddavis@forumcomm.com, jcroman@kare11.com, ahart@kare11.com, klksnews@yahoo.com, ochsnews@yahoo.com, thauser@kstp.com, mfischenich@mankatofreepress.com, baverill@mndaily.com, ntibbetts@mndaily.com, lmccallum@mpr.org, tscheck@mpr.org, swente@republican-eagle.com, jayjohnson@postbulletin.com, lschumacher@stcloudtimes.com, charley.shaw@legal-ledger.com, jragsdale@pioneerpress.com, rrosario@pioneerpress.com, bsalisbury@pioneerpress.com, rstassen-berger@pioneerpress.com, jsullivan@pioneerpress.com, dbrewster@startribune.com, mbrunswick@startribune.com, cdefiebre@startribune.com, pdoyle@startribune.com, ndraper@startribune.com, hopfen@startribune.com, plopez@startribune.com, lsturdevant@startribune.com, bbowring@tpt.org, mlahammer@tpt.org, EEskola, eeskola@cbs.com, pjkessler@wcco.cbs.com, randy@neighborsforrandy.org, bernie@electbernie.org, samantha@russforward4.org, webmaster@thune2007.com, info@melvincarter.org, contact@davidhaasforcitycouncil.org, helgen00005@hotmail.com, stpaulward6@gmail.com, info@pakouhang.com, trudy.moloney@ci.stpaul.mn.us, margaret.egan@ci.stpaul.mn.us, marcia.moermond@ci.stpaul.mn.us, elizabeth.davis@ci.stpaul.mn.us, kenneth.smith@ci.stpaul.mn.us, thomas.davenport@ci.stpaul.mn.us, mkib73@hotmail.com, tim@e-democracy.org, eagledahn1, velma.korbel@state.mn.us, admin.info@state.mn.us, glenn.wilson@state.mn.us, alice.seagren@state.mn.us, cal.ludeman@state.mn.us, deed.customerservice@state.mn.us, dianne.mandernach@health.state.mn.us, dianne.mandernach@state.mn.us, dli.commissioner@state.mn.us, michael.campion@state.mn.us, dan.salomone@state.mn.us, carol.molnau@state.mn.us, michael.pugliese@state.mn.us, tim.marx@state.mn.us, mhfa@state.mn.us, chris.coleman@ci.stpaul.mn.us, citizen.service@ci.stpaul.mn.us, CityofSaintPaul@govdelivery.com, jerry.ludden@ci.stpaul.mn.us, erin.dady@ci.stpaul.mn.us, ann.mulholland@ci.stpaul.mn.us, Nancy.Homans@ci.stpaul.mn.us, Kris.Fredson@ci.stpaul.mn.us, Bob.Hume@ci.stpaul.mn.us, Chris.Rider@ci.stpaul.mn.us, Anne.Hunt@ci.stpaul.mn.us, Nick.Shuminsky@ci.stpaul.mn.us, Joe.Spencer@ci.stpaul.mn.us, Va-Megn.Thoj@ci.stpaul.mn.us, Melvin.Carter@ci.stpaul.mn.us, Vallay.Varro@ci.stpaul.mn.us, Carol.Washington@ci.stpaul.mn.us, Darlyne.Morrow@ci.stpaul.mn.us, Jean.Karpe@ci.stpaul.mn.us, Milyon.Tekle@ci.stpaul.mn.us, Sean.Johnson@ci.stpaul.mn.us, john.harrington@ci.stpaul.mn.us, matt.bostrom@ci.stpaul.mn.us, bob.fletcher@co.ramsey.mn.us, neil.melton@state.mn.us, diverson@pioneerpress.com, aharrington@pioneerpress.com, dbeal@pioneerpress.com, jbjorhus@pioneerpress.com, dfondler@pioneerpress.com, jforster@pioneerpress.com, mhopp@pioneerpress.com, khubbard@pioneerpress.com, rhubbard@pioneerpress.com, sjean@pioneerpress.com, jkrocheski@pioneerpress.com, lsuzukamo@pioneerpress.com, twebb@pioneerpress.com, janice.rettman@co.ramsey.mn.us, chiefclerk@co.ramsey.mn.us, jim.mcdonough@co.ramsey.mn.us, david.twa@co.ramsey.mn.us, victoria.reinhardt@co.ramsey.mn.us, toni.carter@co.ramsey.mn.us, tony.bennett@co.ramsey.mn.us, bonnie.jackelen@co.ramsey.mn.us, jan.parker@co.ramsey.mn.us, rafael.e.ortega@co.ramsey.mn.us, rob.fulton@co.ramsey.mn.us, john.choi@ci.stpaul.mn.us, john.lesch@ci.stpaul.mn.us, lisa.veith@ci.stpaul.mn.us, john.kelly@ci.stpaul.mn.us, jerry.hendrickson@ci.stpaul.mn.us, debbie.montgomery@ci.stpaul.mn.us, dave.thune@ci.stpaul.mn.us, pat.harris@ci.stpaul.mn.us, kathy.lantry@ci.stpaul.mn.us, jay.benanav@ci.stpaul.mn.us, Lee.Helgen@ci.stpaul.mn.us, dan.bostrom@ci.stpaul.mn.us, mranfang@hotmail.com, nathan.stublaski@ci.stpaul.mn.us, steve.schneider@ci.stpaul.mn.us, john.zanmiller@ci.west-saint-paul.mn.us, will.rossbach@ci.maplewood.mn.us, dave.wagner@ci.stpaul.mn.us, dave.schuler@ci.stpaul.mn.us, steve.gleason@ci.stpaul.mn.us, jim.graupmann@ci.stpaul.mn.us, waterinquiries@ci.stpaul.mn.us
CC:Bill4Dahn, Sharon4Anderson, minneapolis@fbi.gov, minneapolis@ic.fbi.gov, askdoj@usdoj.gov, james.lackner@usdoj.gov, rachel.paulose@usdoj.gov, tim.pawlenty@state.mn.us, attorney.general@state.mn.us, rbljohnson@yahoo.com, mami2fine2004@yahoo.com, joel.essling@ci.stpaul.mn.us, scoop@pioneerpress.com, gljoe@am1500.com
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CANDIDATE VA WIDOW-WHISTLEBLOWER WARD 2
SHARON ANDERSON DEMANDS THE
DSI BE ABOLISHED IN ITS ENTIRITY
FOR FALSE STATEMENTS, THEFT, TRESPASS, TREASON
CONSPIRACY TO HARM, INJURE CANDIDATES FOR PUBLIC OFFICE
AND ON THE ST.PAUL CITIZENERY
Mon. July 16th,2007
FOIA DEMAND FOR VALID COMPLAINTS DENIED BY CITY EMPLOYEE
ROBERT HUMPHREY? REFUSAL TO PUT IN WRITING
TECHINALLY IS MALFEASANCE, MISFEASANCE, NONFEASANCE
FOIA Update: The Freedom of Information Act, 5 U.S.C. sect. 552, As Amended By Public Law No. 104-231, 110 Stat. 3048 FOIA - Google Search

The Freedom of Information Act
5 U.S.C. § 552, As Amended By
Public Law No. 104-231, 110 Stat. 3048

Below is the full text of the Freedom of Information Act in a form showing all amendments to the statute made by the "Electronic Freedom of Information Act Amendments of 1996." All newly enacted provisions are in boldface type.

§ 552. Public information; agency rules, opinions, orders, records, and proceedings

(a) Each agency shall make available to the public information as follows:

(1) Each agency shall separately



In a message dated 7/13/2007 4:34:43 P.M. Central Daylight Time, Robert.Humphrey@ci.stpaul.mn.us writes:
Hello Sharon,

Pasted below is a brief complaint history on 697 Surrey. In addition, you requested the organizational structure of the Department of Safety and Inspections. That is also attached.

Have a great Weekend.

--Robert

STAMP - Activities
New Search Help using this report IS Help

Run Date: 07/13/07 04:22 PMFolder Count:20
House#:697 Sort by Most recent Date Starting Date:
Street Name:SurreyEnding Date:
Property Name:
Click on address link to access
GISmo, MapIT, and Ramsey County Info		Click on ID# link below to view detail
AddressDateID # StatusTypeDescription
697 Surrey Ave
05/14/07 07 077615 ClosedPA - Parks Summary Abatement - Garbage RubbishOwner: James R Anderson/Lyle V Rambo - Remove camper trailer form rear yard.
04/19/07 07 064222 ClosedPA - Parks Summary Abatement - Garbage RubbishOwner: James R Anderson/Lyle V Rambo - Remove pile of refuse from rear yard and refuse from camper trailer.
01/31/07 07 016720 Under ReviewCS - CSO Complaint - Interior - ComplaintSmells horrible and junk piled up you can't even see in the front window, the recycling has a horrible stinch
10/05/06 06 240593 ClosedCS - CSO Complaint - Exterior - ComplaintGarbage and refuse
09/18/06 06 206510 OpenRE - Real Estate AssessmentsOwner: James R Anderson/Lyle V Rambo
07/25/06 06 114095 ClosedPA - Parks Summary Abatement - Garbage RubbishOwner: James R Anderson/Lyle V Rambo - Remove recyclable items from blvd., Remove garbage from container in front yard and remove refuse and scattered debris from front and back yard.
07/14/06 06 109897 ClosedCS - CSO Complaint - Exterior - ComplaintGarbage has been in a trailer for four years!
05/19/06 06 084922 ClosedCS - CSO Complaint - Tall Grass - ComplaintTall grass
05/12/06 06 081628 ClosedCS - CSO Complaint - Exterior - ComplaintVehicles, mini van & travel trailor, fence in disrepair w/tarps. Mountains of debris
05/04/06 06 077356 ClosedCS - CSO Complaint - Interior - Complaint5/4/06 Water Shut Off (dj)
02/17/06 06 021557 ClosedCS - CSO Complaint - Opinion - FYI - No Response RequiredREceived a threatening letter from LIEP-Christine Rozack to take the dog and the legal domicle is 1058 Summit. There are also 5 non resident vacant buildings that surrond 697 Surrey where I live and Steve Magner has failed to assure the registration of this properties, yet the City wants to go after a good house at 14 Jessamine.
01/18/06 06 007331 ClosedCS - CSO Complaint - Alley Trash - ComplaintPiles of rubbish thruout yard. Trailer in back. Fencing in disrepair with blue tarps replacing panels. Shed in disrepair.
10/18/05 05 181524 ClosedCS - CSO Complaint - Exterior - ComplaintGarbage, dog feces, broken fence, yard cluttered
06/27/05 05 124376 ClosedCS - CSO Complaint - Exterior - ComplaintJunk in the yard, very messy
03/31/03 03 274528 ClosedCF - CSO Information Request - Information - Counterp.o. for complaint against property
03/26/03 03 272593 ClosedCS - CSO Complaint - Opinion - ComplaintSharon Anderson feels she is being harassed by Animal Control,she was asked for her drivers license and feels this was an infringement on her rights. She wants a response from Animal Control on her e-mail which is: www.shewolfeagle@aol.com
02/27/03 03 261735 Active/IssuedXA - ECLIPS License - Animals - Dog Senior (Lifetime)Licensee: Sharon Anderson - ECLIPS License# 20020000712
03/07/02 02 103675 ClosedCS - CSO Complaint - Interior - ComplaintThere are cat feces and dog feces all over the house. There are many cats in the house, as well as dogs.
02/12/02 02 000712 CanceledXA - ECLIPS License - Animals - Dog Senior*Licensee: Sharon Anderson - ECLIPS License# 20020000712
02/12/02 02 000712 CanceledXA - ECLIPS License - Animals - Dog Senior*Licensee: Sharon Anderson - ECLIPS License# 20020000712


http://www.google.com/url?q=

YouTube - Justice for Barbara Winn

Aaron Foster of the St. Paul Police Department needs to face ...
http://www.blogger.com/terms.ghttp://www.blogger.com/terms.gWatch video - 2 min 43 sec - http://www.blogger.com/terms.ghttp://www.blogger.com/terms.ghttp://www.blogger.com/terms.ghttp://www.blogger.com/terms.ghttp://www.blogger.com/terms.g
www.youtube.com/watch?v=AcCApxyVKjs&
Further the

CouAdult Felony Case Update - County Attorney's Office - Anoka County, MN nty Attorney’s OfficeLawyer List Which robert Johnson is your license>

Further the http://lufsky.blogspot.com/ sceniero is highly repugnant.

Go to the
Adult Felony Trial
Updates page

http://www.blogger.com/terms.g

BlogItBabe2007
http://www.blogger.com/terms.g Candidate profile Sharon4Anderson's Legal BlogBriefs Sharon4Anderson St.Paul City Council Ward2 SA-Blogs2007
LEGAL NOTICE: /s/Sharon4Anderson@aol.com ECF_P165913Pacersa1299 telfx: 651-776-5835: Document's are based on SEC filings, current events, interviews, press releases, and knowledge gained as financial journalists, Private Attorney Generals, Candidates for Public Office documents expressly forbids its writers from having financial interests in securities they recommend to readers, affiliated entities, employees, and agents an initial trade recommendation published on the Internet, after a direct mail publication is sent, before acting on that recommendations, and may contain errors. Investment decisions should not be based solely on theseSHARON-MN-ECF: Judges-Greylord-Libby-Guilty LUFSKY Scap129FAnokaP2697(1976) Cpl James R. Anderson USMC 11022885 Bio for Sharon Anderson , TAKING DL_AOL Journal Legal Eagle SharonAnderson 1 Journalism Ethics Blogger: 1986 Petition Jane Duchene MN Bull SharonScarrellaAndersonUSBriefs - Buzznet Sharon'sFedCases1973to2006_13pdf

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Monday, July 9, 2007

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Sunday, April 22, 2007

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Thursday, March 29, 2007

RICO V ST.PAUL

"UPDATE; Saint Paul Racketeering Lawsuits Motion To Compel"

5 Comments -
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Bob
Bob said...

UNITED STATES DISTRICT COURT
DISTRICT OF MINNESOTA
Frank J. Steinhauser, III, et al., Civil No. 04-2632
JNE/SRN
Plaintiffs,
v. MOTION TO
City of St. Paul, et al., COMPEL DISCOVERY
Defendants.
Sandra Harrilal, et al., Civil No. 05-461
JNE/SRN
Plaintiffs,
v.
Steve Magner, et al.,
Defendants.
Thomas J. Gallagher, et al., Civil No. 05-1348
JNE/SRN
Plaintiffs,
v.
Steve Magner, et al.,
Defendants.
Pursuant to Rule 37 of the Federal Rules of Civil Procedure, Plaintiffs in the above-referenced cases (except Plaintiffs Bee and Lamena Vue in the Harrilal, et al. case) respectfully move the Court for an order compelling Defendants to produce documents and
Case 0:05-cv-01348-JNE-SRN Document 39 Filed 03/15/2007 Page 1 of 2

2
answer interrogatories, and requiring Defendants to pay to Plaintiffs the reasonable expenses incurred in making the motion, including attorney's fees. Counsel for the parties have met and conferred in good faith in an attempt to resolve the discovery dispute, but it appears that the assistance of the Court is required to compel Defendants to comply with the Rules by providing answers and responses to Plaintiffs’ discovery requests. This motion is based on the arguments of counsel, their memorandum of law, and upon all the files, records and proceedings herein.
THE ENGEL FIRM, PLLC
Dated: March 15, 2007 By: /s/ Matthew A. Engel
Matthew A. Engel (Attorney Lic. #315400)
11282 86th Avenue North
Maple Grove, Minnesota 55369
T: (763) 416-9088
F: (763) 416-9089
Attorney for Plaintiffs Gallagher, et. al.
SHOEMAKER & SHOEMAKER, P.L.L.C.
Dated: March 15, 2007 By: /s/ John R. Shoemaker
John R. Shoemaker (Attorney Lic. #161561)
Centennial Lakes Office Park
7701 France Avenue South, Suite 200
Edina, Minnesota 55435
(952) 841-6375
Attorneys for Plaintiffs Steinhauser, et. al. Attorneys for Plaintiffs Harrilal, et. al.
Case 0:05-cv-01348-JNE-SRN Document 39 Filed 03/15/2007 Page 2 of 2

7:17 AM

Bob
Bob said...

UNITED STATES DISTRICT COURT
DISTRICT OF MINNESOTA
Frank J. Steinhauser, III, et al., Civil No. 04-2632
JNE/SRN
Plaintiffs,
v. NOTICE OF MOTION
City of St. Paul, et al., TO COMPEL DISCOVERY
Defendants.
Sandra Harrilal, et al., Civil No. 05-461
JNE/SRN
Plaintiffs,
v.
Steve Magner, et al.,
Defendants.
Thomas J. Gallagher, et al., Civil No. 05-1348
JNE/SRN
Plaintiffs,
v.
Steve Magner, et al.,
Defendants.
PLEASE TAKE NOTICE, that on Friday, the 27th day of April, 2007, at 9:30 a.m., or as soon thereafter as counsel can be heard, in courtroom 8E, United States Courthouse, 300 South 4th Street, Minneapolis, MN 55104, a motion to compel discovery will be made on
Case 0:05-cv-01348-JNE-SRN Document 40 Filed 03/15/2007 Page 1 of 2

2
behalf of the Plaintiffs before Honorable Susan Richard Nelson, Magistrate Judge of Federal District Court for the District of Minnesota.
THE ENGEL FIRM, PLLC
Dated: March 15, 2007 By: /s/ Matthew A. Engel
Matthew A. Engel (Attorney Lic. #315400)
11282 86th Avenue North
Maple Grove, Minnesota 55369
T: (763) 416-9088
F: (763) 416-9089
Attorney for Plaintiffs Gallagher, et. al.
SHOEMAKER & SHOEMAKER, P.L.L.C.
Dated: March 15, 2007 By: /s/ John R. Shoemaker
John R. Shoemaker (Attorney Lic. #161561)
Centennial Lakes Office Park
7701 France Avenue South, Suite 200
Edina, Minnesota 55435
(952) 841-6375
Attorneys for Plaintiffs Steinhauser, et. al. Attorneys for Plaintiffs Harrilal, et. al.
Case 0:05-cv-01348-JNE-SRN Document 40 Filed 03/15/2007 Page 2 of 2

7:20 AM

Bob
Bob said...

UNITED STATES DISTRICT COURT
DISTRICT OF MINNESOTA
Frank J. Steinhauser, III, et al., Civil No. 04-2632
JNE/SRN
Plaintiffs,
v. AFFIDAVIT OF
MATTHEW A. ENGEL
City of St. Paul, et al., IN SUPPORT OF MOTION
TO COMPEL DISCOVERY
Defendants.
Sandra Harrilal, et al., Civil No. 05-461
JNE/SRN
Plaintiffs,
v.
Steve Magner, et al.,
Defendants.
Thomas J. Gallagher, et al., Civil No. 05-1348
JNE/SRN
Plaintiffs,
v.
Steve Magner, et al.,
Defendants.
STATE OF MINNESOTA )
) ss.
COUNTY OF HENNEPIN )
Matthew A. Engel, being duly sworn upon oath, states and deposes as follows:
1
Case 0:05-cv-01348-JNE-SRN Document 42 Filed 03/15/2007 Page 1 of 4

1.
I am an attorney licensed to practice law in the State of Minnesota and admitted to practice in District Court. I am the attorney of record for the Plaintiffs in Thomas J. Gallagher, et. al., v. Magner, et. al. This affidavit is submitted on behalf of all of the Plaintiffs in the above captioned matters in support of Plaintiffs’ Motion to Compel Discovery.
2.
Plaintiffs’ counsel in the Gallagher, et. al., v. Magner, et. al, case served Interrogatories and Requests for Production of Documents via personal service, hand delivery, to Ms. Seeba at her offices on January 30, 2007. Attached hereto as Exhibit “A” is a true and correct copy of the Plaintiffs’ Interrogatories to Defendants and Plaintiffs’ Request for Production of Documents.
3.
Defendants failed to serve Answers to Interrogatories and Responses to Document Requests within the 30 day period allowed under Fed. R. Civ. P. 33(b)(3) and 34(b).
4.
On March 12, 2007, pursuant to Fed. R. Civ. P. 37 (a)(2)(A), attorney John R. Shoemaker, counsel for the Steinhauser, et al. and Harrilal, et al. Plaintiffs, and I met and conferred in good faith with Louise Toscano Seeba, attorney for Defendants in the above entitled matters, in an attempt to resolve the discovery dispute regarding Defendants’ failure to respond to Plaintiffs’ requests for production of documents and interrogatories within the time permitted by the Rules.
2
Case 0:05-cv-01348-JNE-SRN Document 42 Filed 03/15/2007 Page 2 of 4

5.
During our meeting on March 12, 2007, Ms. Seeba made clear that Defendants’ responses to Plaintiffs’ discovery requests and answers to interrogatories would not be served on Plaintiffs before the non-dispositive motion deadline of March 15, 2007.
6.
Plaintiffs’ counsel informed Ms. Seeba that due to the deadline of March 15, 2007, for filing and serving motions to compel discovery, Plaintiffs found it necessary to prepare a motion to compel for filing by the deadline.
7.
Plaintiffs’ counsel agreed to allow Defendants’ counsel to serve answers to interrogatories and responses to requests for production of documents by March 30, 2007, with Plaintiffs seeking to obtain a hearing date on the motion to compel for a date after the middle of April, 2007. Ms. Seeba indicated that certain documentation subject to the Plaintiffs’ requests for documents would be available for review by Plaintiffs’ counsel starting March 17, 2007, and additional documentation would be made available for review on a continuing basis over the remainder of March 2007 and into early April 2007. Plaintiffs agreed to perform interim document review sessions as Defendants’ counsel obtained documents from the various departments within the City of St. Paul.
8.
Thereafter, I submitted a letter to Defendants’ counsel confirming the agreements of counsel for the continued discovery efforts. Attached hereto as Exhibit “B” is a true and correct copy of the March 13, 2007, correspondence I sent to Ms. Seeba.
3
Case 0:05-cv-01348-JNE-SRN Document 42 Filed 03/15/2007 Page 3 of 4

FURTHER YOUR AFFIANT SAYTH NOT.
Dated: 3/15/07 s/ Matthew A. Engel__
Matthew A. Engel
Subscribed and sworn to before me
this 15th day of March, 2007.
s/ Erik L. Vakula
Notary Public
Under Seal
4
Case 0:05-cv-01348-JNE-SRN Document 42 Filed 03/15/2007 Page 4 of 4

7:24 AM

Bob
Bob said...

UNITED STATES DISTRICT COURT
DISTRICT OF MINNESOTA
Frank J. Steinhauser, III, et al., Civil No. 04-2632
JNE/SRN
Plaintiffs,
v. AFFIDAVIT OF
JOHN R. SHOEMAKER
City of St. Paul, et al., IN SUPPORT OF MOTION
TO COMPEL DISCOVERY
Defendants.
Sandra Harrilal, et al., Civil No. 05-461
JNE/SRN
Plaintiffs,
v.
Steve Magner, et al.,
Defendants.
Thomas J. Gallagher, et al., Civil No. 05-1348
JNE/SRN
Plaintiffs,
v.
Steve Magner, et al.,
Defendants.
STATE OF MINNESOTA )
) ss.
COUNTY OF HENNEPIN )
John R. Shoemaker, being duly sworn upon oath, states and deposes as follows:
Case 0:05-cv-01348-JNE-SRN Document 43 Filed 03/15/2007 Page 1 of 5

1.
I am an attorney licensed to practice law in the State of Minnesota since 1984 and admitted to practice in this Court. I am the attorney of record for the Plaintiffs in Frank J. Steinhauser, et al., v. Magner, et al. and for Plaintiffs Sandra Harrilal and Steven R. Johnson in Sandra Harrilal, et al. v. Magner, et al. I am submitting this affidavit in support of Plaintiffs’ joint Motion to Compel Discovery in all three of the consolidated-for-discovery cases herein.
2.
Interrogatories and Requests for Production of Documents in Steinhauser, et. al., and Harrilal, et al., cases were served by hand delivery on Defendants’ attorney, Louise Seeba, at her offices on January 31, 2007. Attached hereto as Exhibit “A” is a true and correct copy of the Certificate of Service (See Paragraph No. 10 below for a description of the specific discovery requests that were served by Plaintiffs on Defendants).
3.
Defendants failed to serve Answers to Interrogatories and Responses to Document Requests within the 30 day period allowed under Fed. R. Civ. P. 33(b)(3) and 34(b). Defendants’ Responses to Requests for Production of Documents and Answers to Interrogatories were due for service on Plaintiffs on March 2, 2007, but Defendants failed to timely respond. Defendants’ counsel did not seek an extension of time to respond and did not in any other way contact me concerning the discovery responses that were due from Defendants by March 2, 2007.
4.
On March 9, 2007, I forward a letter to Ms. Seeba regarding Defendants’ failure to serve discovery responses and I scheduled a “meet and confer” for
2
Case 0:05-cv-01348-JNE-SRN Document 43 Filed 03/15/2007 Page 2 of 5

March 12, 2007. Attached hereto as Exhibit “B” is a true and correct copy of my March 9, 2007, letter.
5.
On March 12, 2007, pursuant to Fed. R. Civ. P. 37 (a)(2)(A), and Local Rule 37.1, attorney Matthew Engel, counsel for the Gallagher, et al. Plaintiffs, and I met and conferred in good faith with Ms. Seeba in the above entitled matters, in an attempt to resolve the discovery dispute regarding Defendants’ failure to respond to Plaintiffs’ requests for production of documents and interrogatories within the time permitted by the Rules.
6.
During our meeting on March 12, 2007, Ms. Seeba made clear that Defendants’ responses to Plaintiffs’ discovery requests and answers to interrogatories would not be served on Plaintiffs before the non-dispositive motion deadline of March 15, 2007.
7.
Plaintiffs’ counsel informed Ms. Seeba that due to the deadline of March 15, 2007, for filing and serving motions to compel discovery, Plaintiffs found it necessary to prepare a motion to compel for filing by the deadline.
8.
Plaintiffs’ counsel agreed to allow Defendants’ counsel to serve answers to interrogatories and responses to requests for production of documents by March 30, 2007, with Plaintiffs seeking to obtain a hearing date on the motion to compel for a date after the middle of April, 2007. Ms. Seeba indicated that certain documentation subject to the Plaintiffs’ requests for documents would be available for review by Plaintiffs’ counsel starting March 17, 2007, and additional documentation would be made available for review on a continuing
3
Case 0:05-cv-01348-JNE-SRN Document 43 Filed 03/15/2007 Page 3 of 5

basis over the remainder of March 2007 and into early April 2007. Plaintiffs agreed to perform interim document review sessions as Defendants’ counsel obtained documents from the various departments within the City of St. Paul.
9.
On March 14, 2007, I forwarded a letter to Defendants’ counsel via facsimile transmission confirming the agreements of counsel reached during the March 12, 2007 meeting. Attached hereto as Exhibit “C” is a true and correct copy of the March 14, 2007, correspondence from John R. Shoemaker, Esq. to Louise Toscano Seeba, Esq.
10.
Each of the following discovery requests was served by Plaintiffs on Ms. Seeba and Defendants via hand delivery through Metro Legal Services on January 31, 2007:
a.
Attached as Exhibit “D” is a true and correct copy of Plaintiffs Harrilal and Johnson’s Interrogatories to Defendants;
b.
Attached as Exhibit “E” is a true and correct copy of Plaintiffs Harrilal and Johnson’s Request for Production of Documents;
c.
Attached as Exhibit “F” is a true and correct copy of the Steinhauser Plaintiffs’ Interrogatories to Defendants (Set II).
d.
Attached as Exhibit “G” is a true and correct copy of the Steinhauser Plaintiffs’ Request for Production of Documents to Defendants (Set II).
4
Case 0:05-cv-01348-JNE-SRN Document 43 Filed 03/15/2007 Page 4 of 5

FURTHER YOUR AFFIANT SAYTH NOT.
Dated: 3/15/07 s/ John R. Shoemaker__
John R. Shoemaker
Subscribed and sworn to before me
this 15th day of March, 2007.
s/ Paul F. Shoemaker
Notary Public
Under Seal
5
Case 0:05-cv-01348-JNE-SRN Document 43 Filed 03/15/2007 Page 5 of 5

7:27 AM

Posted by Sharon 4Anderson at 10:02 AM 0 comments

Sunday, January 7, 2007

Whistleblower's Blog via Babe

Constitutionality of State License's
Lawyers License's:Separation Powers
Has the State of Minnesota, County of Ramsey,
City of St. Paul by DFL Judges wilful neglience, contrary
ACTING IN CONCORT TO CAUSE IRREPARABLE HARM, INJURY,STEALING E-COMMERCE PROPERTY RIGHTS TO UNDERMINE FEDERAL LAWS?
, Sharon is calling for the criminal prosecution and arrest of city attorney Judy Hanson for having secret hearings without the cop present, denial of jury trial, failure to answer the crosscomplaints of VA Widow Sharon Anderson therefore MS 609.51SimulatingLegProcess MS 609.385 Treason MS 176.312Aff Pred Senile Judge Larry Cohen has been a Thorn in Sharons Side for 30 years.
"Larry Dease Thanks for call 8Mar06 stating you would send the Computer Docket Sheet: TCIS TO-05-011101 Ticket 905191492 alleging Illegal Right Turn, at a 4 way stopsign on Case & Payne."
MEMORANDUMN: NO STATUTE OF LIMITATIONS ON FRAUD OR MURDER
Apr. 2007 will be (2) years unabated by Public Officials Further Unlicensed Cop Cyr Abraham, Wilful Neglience ofSenile Judge Larry Cohen MS 546.27 Order 90 dys TO ISSUE
THEREFORE: 5fEB07 DEFAULT IS NOTICED WITH
FBI AND US ATTORNEY MUST TRIGGER INVESTIGATIONS.
PUNATITIVE, COMPENSATORY, TORT DAMAGES OVER
$75 THOUSAND DOLLARS FOR EACH YEAR OF DENIAL.
REFUSAL OF THE STATE ATTORNEY MS 171.02 DL validityDisabilityTrafficFee_8GENERAL LORI SWANSON TO DEFEND THE STATUTE MS 171.16 30 days suspension
MS 645.Canons of Construction is cause for Removal from Office of Public Trust.



Please register ,Robert Barnes writings are will worth it.


Dated: Sun. 7Jan2007
To St. Paul Police Chief John Harrington and Sheriff Bob Fletcher, forensic evidence to reinstatae Drivers License
award Punatitive, Compensatory Damages 5th Amendment "taking" clause

for extensive Background Check of Sharon Anderson aka Chergosky-Peterson.



GOD BLESS AMERICA AND ITS CITIZENERY




AFFIDAVIT OF SHARON SCARRELLA ANDERSON AKA BLOGINBABE

In re: Scarrella for Associate Justice 221NW2nd562 (1974)

Denied Judicial Employment as Sharon is Just a Nonlawyer Citizen.


WHISTLEBLOWERS: MEDIA, MINNESOTA MASSACRE

Submitted in good faith for educational purposes

Further the State,Federal Judiciary must disclose ALL.

NO STATUTE OF LIMITATIONS ON FRAUD OR MURDER.





By information and belief Alice Krengel EMINENT DOMAIN IN MINNESOTA: Case study Alice Krengel, 823 Allen, WSP hearing http://www.mncourts.gov/ tues. 9Jan07,


Hey Paralegals, Attorney Pro Se etc, Whistleblowers, even Licensed Lawyers???

Background checks are welcome to resolve Homegrown http://www.seniorqueen.blogspot.com/


Its time WE break open the Golden Doors of Access to the US Supreme Court.

from the Graves of Sharons Tenants in Common We The People Foundation et al

Health Care AbuseMN Bull against We the People, US Court Precedant via Drugged Delusions. must be abated.





RICO
Bond v. Revenue 691NWRep2d832

Doing what I can after 30 years of trying to quiet titles, PROTECT OUR HERITAGE.


HUMBLY SUBMITTED: 7Jan2007 Memorandumn: Sharon has been denied her Aitkin and Buck Lake Propertys over 5 years, Insurance companys have wilfully failed to protect Sharons Commerce Claims, via Corrupt Judiciary.......


LEGAL NOTICE: document's are based on SEC filings, current events, interviews, press releases, and knowledge gained as financial journalists, Private Attorney Generals, Candidates for Public Offices, and may contain errors. Investment decisions should not be based solely on these documents Bio for Sharon Anderson , expressly forbids its writers from having financial interests in securities they recommend to readers, affiliated entities, employees, and agents an initial trade recommendation published on the Internet, after a direct mail publication is sent, before acting on that recommendation. TAKING DL_AOL Journal Candidate profile
Senior QueenCandidate2007 Legal Eagle SharonAnderson 1 Journalism Ethics Blogger: Dashboard SharonScarrellaAnderson 1986 Petition Jane Duchene MN Bull SharonScarrellaAndersonUSBriefs - Buzznet Photo Sharing Community Sharon'sFedCases1973to2006_13pdf Anderson + Advocates http://www.sharonanderson.org/ http://www.sharon4anderson.org
Posted by Sharon 4Anderson at 11:23 AM 1 comments
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