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The Healy Project, Court File No. 27-CV-14-7064
Judge Marilyn Brown Rosenbaum

Michael Crow and Linda Crow,


) ss.

I, Michael Crow, being first duly sworn and on oath, state as follows:
1. I, along with my wife, are the owners of real property located at 2320 Colfax
Avenue in Minneapolis, Minnesota (the Property). I make this Affidavit based upon my own
personal knowledge, unless otherwise indicated that the same is made upon information and
2. I have owned the Property for approximately twenty-three years. I purchased the
Property in 1991 after a fire significantly gutted the second and third floors of the Property. The
Property is presently, and has been since the time of my purchase of the same, a rooming house.
The Property is 15 units. As a rooming house, the tenants have separate sleeping
quarters/bedrooms which lock, but there are common bathrooms and a common kitchen. The
rooming house concept of a business is an outdated business concept. Not many such
accommodations exist anymore in the City of Minneapolis, and I have had a difficult time in
recent years retaining reliable tenants in the Property. In essence, the Property is not an

attractive piece of real estate economically as it is due to the outdated nature of this kind of
3. I have experienced a number of health related issues in recent years, including
two open heart surgeries and a back surgery. I am in need of another back surgery which I have
put off for the moment. I used to manage and take care of the Property, but I am no longer able
to do so because of my health. I have to hire out a manager/managers to take care of the
Property which makes the same even less economically viable for me.
4. Because of my health, my financial situation, and the nature of the Property, I
explored selling the Property. I retained a realtor to assist in the sale process. I have a purchase
agreement to sell the Property to a developer who would intend to demolish the Property and
redevelop the same.
5. In the twenty-three years that I have owned the Property, the City of Minneapolis,
twice over, inspected the Property to attempt to make a determination as to whether the Property
was a historical resource. On both occasions, the City officials told me that the Property was not
a historical resource. I believe, as this is what the City inspectors/officials told me, that a part of
the Citys determination was based on the fact that the Property had suffered at least two fires in
its history and had been significantly changed/updated from its original form when it was built in
the late 1800s or early 1900s. In addition, Dr. John Smoley, staff for the City of Minneapolis,
also evaluated the Property in 2013 and at meetings involving the Property, concluded that the
Property did not meet the definition of a historical resource. Again, a large factor in Mr.
Smoleys conclusion is based on the changes/remodeling done on the Property, as well as the
fact that the Property is not a great example of Mr. Healys work given its condition and the fact
that many other Healy homes exist in Minneapolis. See Heritage Preservation Commission

Minutes from April 16, 2013, a true and correct copy of which is a portion of Exhibit A attached
6. Upon my attempted sale of the Property to a developer and the developers and/or
my applications to redevelop the Property, including an application for a demolition permit,
some vocal members of the community, including Anders Christianson, who is the person in
control of or behind the present Plaintiff, objected. The Plaintiff or these persons have been a
part of a long drawn out appeals process with the City of Minneapolis already.
7. The developer will only purchase the Property if it is allowed to demolish the
existing structure and develop the Property as it desires. The demolition permit has been
approved by the City of Minneapolis already, and I believe/understand that the developer has
preliminary approvals for its redevelopment plan.
8. The Plaintiffs contention is that the Property is a historical resource because it
was built by T.P. Healy. Mr. Anders Christianson appears to be the head of the Plaintiff, and he
promotes himself as a person who does restoration work himself for profit.
9. As previously stated, I purchased the Property in 1991 after a fire gutted the
second and third floors of the Property. These floors were completely redone and the interior of
the Property is hotel-like (especially on the 2
and 3
floors), not anything like its original
condition. Also, when the remodeling was done after the fire, the building had to be brought up
to the Citys code at the time.
10. In addition to significant interior remodeling done in follow up to the fire, I also
caused vinyl siding to be put on the exterior of the Property in 2002. Also, all of the previous
wooden windows on the Property have been replaced with vinyl windows.

11. True and correct copies of various photographs/reports as well as findings or
reports from City officials which show how much the Property has been extensively
remodeled/changed since its original construction and is not historical are marked as Exhibit A
and attached hereto.
12. The Planning/Zoning Commission, by a vote of 5 to 1, and the full City Council,
by a vote of 11 to 2, studied and approved a demolition permit for the Property.
13. Plaintiffs motion paperwork alludes to other offers to purchase the Property,
either by Plaintiff or persons associated with Plaintiff. However, what Plaintiff does not say is
that the only offer made occurred on April 21, 2014, two days prior to the full hearing by the
Minneapolis City Council on the demolition permit, and the offer was not a serious financial
offer as it was $200,000 less than the purchase agreement that exists with the developer.
14. The purchase agreement that I have for the Property with the developer is for a
total of $600,000, and the developer has been involved in the process since 2012. I am
concerned that further delays in the developer being able to proceed may cause the developer to
walk away from the deal which would cause significant financial loss and harm to me.

Michael Crow

Subscribed and sworn to before me
This ___ day of May, 2014.

Notary Public