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Memo- City of Hopkins/ABJ Enterprises, Inc. MEMORANDUM TO: Dick Nowlin ~a . '--?A. Marc J Manderscheid (ext. 36~ / . ( I '. FROM: DATE: May 15, 1997 RE: City ofHopkins/ABJ Enterprises, Inc. On JlUle 7, 1996, attorney Kirk Schnitker submitted a "relocation claim summary" to the City of Hopkins on behalf of ABJ Enterprises, Inc., J III Properties, and Cornerstone Companies of Minnesota, Inc. The three claims totaled $157,455.20. A series of motions and negotiations involving both the condemnation matter and the relocation claim ensued. In late JlUle, the claimants were provided $50,000 for moving costs by the City of Hopkins as a down payment, and to insure that the claimants would have the money to move their personal property. On August 14, 1996, I sent a letter to Mr. Schnitker formally denying the relocation claim. The reasons for the denial were set forth in my letter. Among the reasons for rejecting the claimants' claims was because the "relocation claim summaries" contained no documentation of actual expenses incurred. I explained to Mr. Schnitker what type of docmnentation and support would be required in order that the City of Hopkins could make proper relocation and reestablishment payments. On August 15, 1996, Mr. Schnitker presented, for purposes of settlement only, a redrafted relocation claim in the amolUlt of $130,640. He asked for a prompt hearing on the entitlement to the claimed relocation benefits. In the ensuing months, Mr. Schnitker was apparently replaced as cOlUlsel for the claimants by attorney Bruce Malkerson. I advised Mr. Malkerson as to the status of the relocation claim, the reasons why the City denied the claim, and the types of docmnentation which would be needed to support payment of any additional relocation benefits. My last communication with Mr. Malkerson was by telephone in December 1996. It is my belief that Mr. Malkerson clearly lUlderstands that "the ball is in his court" and that if the claimants wish to continue to pursue their claim, they must provide additional documentation. I am continuing to monitor this situation. Because the obligation is upon the claimants to document their claim, I see no reason for the City to take any further action at this time. MJM\9169