Saint Paul Racketeering Law Suit #3, Victims Gallagher, Collins & Dadder's Continued

Racketeering and Illegal Code Enforcement
Directed Against Plaintiffs Gallagher. Collins and Dadder’s on various other rental properties.

1 1 9 .Defendants’ discriminatory and illegal code enforcement activity against Gallagher,Collins and Dadder’s continues to this day. Code enforcement officers prepared and mailedto Dadder’s written Correction Orders and Summary Abatement Orders of their rental properties where in they made petty, malicious and false statements about claimed code violations; many of the entries in the written Correction Orders issued by the code 28 Case Document l-l Filed Page 29 of 57 enforcement officers to Dadder’s were false and calculated to make the Dadder’s properties look bad.
1 2 0 .Cassidy’s June 20, 2005 Summary Abatement Order cited 643 Watson for piles of dirtand yard waste.
1 2 1 .Senty’s April Summary Abatement Order cited 1524 Carroll for the door on thenorth side of garage.
122.Cassidy’s February 8, 2005 Correction Order cited 624 James for rubbish and household items.
1 2 3 .Cassidy’s December 16, 2004 Summary Abatement Order cited 543 Michigan for household items and house and garage numbers.
1 2 4 .Magner’s December Summary Abatement Order cited 250 Duke for a tool box,tires and a couch.
1 2 5 .Essling’s September Correction Order cited 974 James for rubble and doors.
1 2 6 .Cassidy’s September Summary Abatement Order cited 547 Michigan for carpetand pools.
1 2 7 .Cassidy’s September 8, 2004 Summary Abatement Order cited 624 James for plastic anda battery.
1 2 8 .Cassidy’s August 23, 2004 Correction Order cited 547 Michigan for pools, carpet microwave.
1 2 9 .Yannarelly’s July 29, 2004 Correction Notice 1532 Concordia for lack ofservice (after the tenant failed to pay the utility bill).and a water
1 3 0 .Essling’s July 28, 2004 Summary Abatement Order cited 624 James for couches, wood,and cardboard.29 Case Document l-l Filed Page 30 of 57
131.Schiller’s July 21, 2004 Summary Abatement Order 974 James for items and tall grass along the alley.
132.Cassidy’s June 28, 2004 Correction Order cited 250 Duke for a couch and storm door,vehicle parked on an unimproved surface, and scrape and paint garage.
1 3 3 .Yannarelly’s June 25, 2004 Correction Order cited 1500 Concordia for expired plates ona vehicle.
1 3 4 .Yannarelly’s June 25, 2004 Correction Notice cited 15 12 Concordia for peeling paint on siding and expired tabs.
1 3 5 .Cassidy’s June 17, 2004 Correction Order cited 624 James for a door and railing and birds nesting in the siding.
136.Magner’s June 14, 2004 Summary Abatement Order cited 643 Watson for items in the rear and side yard area.
1 3 7 .Senty’s April Summary Abatement Order cited 509 Bay for north side basement windows.
1 3 8 .Schiller’s April 19, 2004 Vehicle Abatement Order cited 551 Michigan for expired tabson a vehicle.
1 3 9 .Schiller’s April 19, 2004 Summary Abatement Order cited 551 Michigan for items around the building.
140.Schiller’s April 19, 2004 Summary Abatement Order cited 547 Michigan for items alongthe alley and under the side steps.
141.Schiller’s April 9, 2003 Correction Notice cited 543 Michigan deteriorated paint and deteriorated
142.Schiller’s January 23, 2003 Summary Abatement Order cited 547 Michigan for items 30 Case Document l-lFiled Page 31 of 57 along the building, under the front steps, and under the front porch.
1 4 3 .A code enforcement officer’s November 20, 2003 Correction Notice cited 543 Michigan for deteriorating paint and deteriorating and fascia.
1 4 4 .Due to the volume of false and petty orders issued by the city, and due to the behavior and items used by tenants which a landlord cannot control (yard furniture, kiddy pools and birds nesting), Gallagher, Collins and Dadder’s attempted but could not keep up with theCity’s requirements and therefore incurred many reinspection fees and excessive consumption invoices.
1 4 5 .Magner, Cassidy, Essling, Senty, Urmann and John Doe and JaneDoe, worked together with Kelly and Dawkins against each plaintiff to run them out of townby illegally using legitimate tools in the law and city code to interfere with the Plaintiffs business by driving up the cost of doing business for the benefit of the city and other competitors in the low income housing market, including PHA, whom on information and belief, receives beneficial treatment.
1 4 6 .As a direct result of the constant discrimination and illegal code enforcement treatment and racketeering activity directed at Gallagher, Collins and Dadder’s by said Defendants, allat the direction or with the approval of Dawkins and Kelly, Gallagher, Collins and Dadder’swere injured in their rental business and incurred unnecessary expenses, fees and lost profitsand Gallagher, Collins and Dadder’s were thereafter forced to sell more than 20 of their realestate investment properties in the City of St. Paul.
147.The illegal actions against Gallagher, Collins, Dadder’s and Allison as described above were accomplished to further the racketeering activity of Defendants.