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Ryan Development Complaint

Ryan Development Complaint

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Published by eric_roper

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Published by: eric_roper on Dec 11, 2013
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 STATE OF MINNESOTA FOURTH JUDICIAL DISTRICT COUNTY OF HENNEPIN CIVIL DIVISION Stephanie Woodruff, Dan Cohen and Paul Ostrow, Plaintiffs COMPLAINT FOR INJUNCTIVE AND v. DECLARATORY RELIEF The City of Minneapolis, Defendant I Plaintiff Stephanie Woodruff is a resident of the City of Minneapolis and the Vice Chair of the City of Minneapolis Audit Committee. II Plaintiff Dan Cohen is a resident and owner of homesteaded property in the City of Minneapolis and served on the Minneapolis City Council from 1965-1969 and served as Council President from 1967-1969. III Plaintiff Paul Ostrow is a resident and owner of homesteaded property at 2239 Arthur Street NE and served on the Minneapolis City Council from 1997-20009 and served as Council President from 2002-2005... IV Defendant City of Minneapolis is a municipal corporation and a political subdivision of the State
of Minnesota (hereinafter “the City”)
 V. The Minnesota Sports Facilities Authority is an agency of the State of Minnesota established
pursuant to Minnesota Statutes 3.8842 (hereinafter “MSFA”)
 VI. The Ryan Development is a proposed development of a parking ramp, a public park, skyways, office space and residential development in the area immediately surrounding the site for the
new Vikings stadium (hereinafter “Ryan Development.”)
 The Ryan Development consists of five city blocks immediately adjacent to the proposed Vikings Stadium designated as Blocks 1
 –
 5. (See Exhibit A)
 
 VII In May of 2013, the Minneapolis City Council passed a resolution granting local approval to Chapter 299 of Session Laws 2012. The City Council also considered and approved a financing plan based upon a staff report and financial projections presented to the Ways and Means/Budget Committee in May 2012 (See Exhibit B). VIII In June of 2013, the Minneapolis City Council approved an action giving concept approval to the Downtown East Development Project. The Council action and all the documents presented to the Community Development Committee are attached as Exhibit C. IX On December 9, 2013, the City Clerk for the City of Minneapolis posted online Term Sheets, proposed bond resolutions and resolution establishing an Industrial Development District documents and made those documents available to the public for the first time. Those documents are attached collectively as Exhibit D. X On December 10, 2013, the Community Development Committee for the City of Minneapolis sent forward to the Ways and Means/Budget Committee and the Minneapolis City Council an action to authorize execution of contract documents and the issuance of 65 million dollars in general obligation bonds to finance the Ryan Development. XI The Term Sheet indicates that the City and the MSFSA intend to execute a contract naming the Minnesota Vikings as a third party beneficiary to the contract. If the contract is executed, the City may become liable even if the bond issue or development agreement is later deemed invalid by the Court. XII Final approval of the bond issuance and development agreement is on the agenda of the City Council for December 13, 2013. COUNT ONE: CITY EXPENDITURES CONTRARY TO STATE LAW XIII Plaintiff re-alleges Paragraphs I through VI.
 
 XIV Chapter 299 of Minnesota Session Laws 2012 comprehensively governs the design requirements and funding mechanisms for the construction of a new Vikings stadium. The City of Minneapolis as a political subdivision of the state cannot exceed the authority granted to the City under the act. XV. M.S. 473J.11 Sub
. 4(b) limits the City’s share of “stadium costs” for the required stadium design
to $150,000,000. XVI Upon information and belief, the City has already pledged $150,000,000 for the construction of
the “stadium” as defined by M.S. 473J.03
Sub. 8. XVII
M.S. 473J.03 defines “stadium costs” subject to the City’s maximum contribution as including “stadium infrastructure.”
Sub
. 10 defines “stadium infrastructure” to include plazas, parking structures, rights of way, connectors, skyways and tunnels.”
 XVIII
The proposed “Ryan Downtown East Project Term Sheet dated December 6, 2013(Attached as
Exhibit E and
hereafter “Proposed Term Sheet”) includes the following as estimated public costs
of the Ryan Project to be funded by the City:
-
 
Purchase Price for Urban Park to be utilized by Vikings on game day: $20,000,000
-
 
City portion of purchase price for Block 1 Ramp: $32.63 Million
-
 
Additional site costs for Park: $4.98 Million XIX The urban park to be paid for by the City as a part of the Ryan Development satisfies the requirements of Sub
. 3(6) which provides for “elements sufficient to provide community and civic uses as determined by the authority.” City expenditures for this required desi
gn element, at least to the extent that the Minnesota Vikings fail to pay fair market value for their use of the park and to the extent that those expenditures cause the city to exceed the limit on city funding of stadium costs, violates the limitation on city funding for stadium improvements. XX

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