Saint Paul Racketeering Lawsuit #3 Continued, 1524 Carroll

100 .In March of 2005, Enforcement Officer Senty, supervised by Dawkins, commenced the illegal harassment against Dadder’s (and therefore Allison, who purchased the unit from 24 Case Document l-lFiled Page 25 of 57Dadder’s) by posting a “Vacant Building” sign on the occupied property located at 1524 Carroll. This property was in fact occupied by tenants. Senty ignored the obvious occupancy of the home and posted the home as vacant. Because of the Vacant Building posting and order prohibiting occupancy of the home, Dadder’s was forced to move the tenant to a different rental property and Allison has been forced to leave the unit empty.

1 0 1 .Gallagher spoke with Senty and also met with Dawkins on April 1, 2005 to inquire why Senty had posted the home. Gallagher informed Senty that the home was in fact occupied bytenants and that the posting was wrong. Gallagher had copies of a signed lease and bank deposit slips for paid rent. Senty responded by stating that he could get affidavits from the neighbors that the property had been empty for six months.

1 0 2 .Gallagher was forced to tile an appeal of Senty’s vacant building posting on Allison’srental unit (although 1524 Carroll was sold to Allison, Gallagher continued to receivethe paperwork from the City) through the City Council legislative hearing process. After waiting for several weeks for the decision of the legislative hearing officer (during whichtime the property remained empty), the legislative hearing officer refused to overturn thevacant posting on appeal because the Section 8 lease which Gallagher produced expired inJanuary. However, the tenant remained in the building until approximately February of 2005, and Gallagher moved the tenant to another rental property as the sale to Allison took place on February

103.Many of the claimed code deficiencies at the 1524 Carroll rental property are due tothe tenant’s behavior. For example, the property has been cited on more than one occasion because the tenant leaves the service door to the garage open.

1 0 4 .Magner prepared and mailed a Vacant Building Registration Fee Warning Letter dated2 5Case Document l-lFiled Page 26 of 57May 4, 2005 to Dadder’s (at their former address in St. Paul) requiring $250.00 for administrative costs or the owners will be subject to a criminal Summons and Complaint.Even though there were tenants in the unit, signed leases and bank deposit slips showing rent payments, Dawkins, Magner, Senty and others used the vacant building procedure as leverage against Gallagher, Collins, Dadder’s and Allison to illegally remove the grand fathering protections of their older building under Minnesota law and to force them into having code compliance inspection and certification process on the Carroll property.

1 0 5 .Dawkins, Magner, Senty and others working for the City targeted both Dadder’s and Allison (the prior and current owner of the Carroll rental property) as part ofillegal scheme to hold landlords responsible for all adverse tenant behavior, including tenant caused damage to rental properties in the City, all in an effort to extort property andother rights from landlords to the benefit of the City and to Dawkins, Magner and others personally.

1 0 6 .Additionally, by illegally removing the grand fathering protections of older City homes and buildings and demanding full “Code Compliance Inspections and Certificates” before allowing the re-rental of the targeted properties, or by declaring a property as vacant,Defendants ensured that the targeted property owners would not be able to afford to rent onceagain to the low income minority tenants in the properties targeted.

1 0 7 .The Carroll rental property owned now my Allison is currently registered as avacant building site. As a direct result of said Defendants’ wrongful conduct directed against Gallagher, Collins, Dadder’s and Allison, they have sustained damages the loss of rent afterMarch 2005.26