1994-09-06 CC Closed Meeting 9:10 p.m.AiC` 1 ,1_,
September 6, 1994
-a ,Z t-vil le City Hall 9:10 PM
PRESENT Mayor Mike Potter, Councilritembers Duane Berning,
Albert Barthel, Sharon Anderson and John Vetsch, City Administrator
Dale Powers, City Clerk T,inda Houghton and City Attorney Mike Couri
Mayor Potter called the closed meeting to order. The purpose
of the meeting is to discuss a possible settlement of the lawsuit
between the City and Ralph and Helen Ackerman.
Attorney Couri presented the Stipulation and Settlement
Agreement drafted in the Ackerman lawsuit and reviewed the major
points of the agreement (Attached to these minutes). Couri stated
that this a fairly tight document that can be enforced by the court
system. Paragraph 8 on Page 2 of the agreement calls for the name
of the septic system inspector. This has not yet been agreed upon,
although Couri is recommending either EcoLab from Elk River or S
& P Testing from Hanover. Couri is awaiting word from Ackerman's
attorney on this item.
Barthel made a motion to authorize the City to enter into the
Stipulation and Settlement Agreement to settle the Ackerman
lawsuit. The name of the septic system inspector will be inserted
when agreed upon. Anderson seconded the motion. All voted aye.
Vetsch made a motion to adjourn the closed meeting at 9:29 PM.
Linda Houghton, Clerk
STATE OF MINNESOTA
COUNTY OF WRIGHT
City of Albertville, Minnesota,
Plaintiff
VS.
Ralph Ackerman and
Helen Ackerman.
Defendants.
DISTRICT COURT
TENTH JUDICIAL DISTRICT
Other Civil - Ordinance Violation
Court File No.
STIPULATION AND
SETTLEMENT AGREEMENT
WHEREAS, the City of Albertville ("City") has brought an
action against Ralph and Helen Ackerman (collectively "Ackermans")
alleging violations of the City zoning ordinance, the City
ordinance regulating dogs and the City ordinance regulating on -site
sewage systems; and
WHEREAS, the Ackermans have counterclaimed against the City
seeking damages as a result of alleged City action; and
WHEREAS, the City and Ackermans seek to compromise their
claims in a manner that will satisfy all parties; and
WHEREAS, the City and Ackermans seek to reduce the terms of
this agreement to a writing that can be recorded at the Wright
County Recorder's office;
THEREFORE, the City and Ackermans agree as follows:
1. The Ackermans will, by August 15, 19941 permanently remove
from the premises all adult male dogs and all adult female
dogs except:
a. two adult female dogs of the Ackerman's choosing.
b. One dog, which dog belongs to the granddaughter of the
Ackermans. Said dog may be on the property periodically
when said granddaughter is visiting the Ackermans, but
said dog shall not be bred by the Ackermans nor shall the
Ackermans raise, care for or sell any puppies from said
dog.
2. The Ackermans will bring their puppy housing facility (the
white lean-to building attached to the barn located on the
Ackerman premises) up to state standards for the keeping of
dogs and will only house puppies in the designated puppy
housing facility.
3. Annual puppy sales shall be limited to 353 puppies (the total
number of puppies sold in 1991) and shall be deemed a pre-
existing use to the extent of 353 puppy sales per year.
4. The Ackermans shall be allowed to keep a maximum of 50 puppies
on the premises at any one time, provided the Ackermans'
facilities can house 50 puppies while meeting all state
requirements for the keeping of dogs. If the facility cannot
meet said requirements for 50 puppies, the Ackermans shall be
limited to the number of puppies which can be housed while
meeting all state requirements, which in no case shall exceed
50 puppies at any one time.
5. Ackermans agree to provide the City with quarterly sales
reports and supporting documentation (invoices, etc.) on a
quarterly basis so long as the operation exists.
6. The Ackermans, sales and breeding operations will not exceed
the criteria set forth above, and the City and the Ackermans
acknowledge that the puppy sales operation (to the extent
allowed as set forth above) is a pre-existing, non -conforming
use under the City,s zoning ordinance.
7. As a part of this agreement, the Ackermans agree to execute a
dismissal of all of their claims against the City, its agents,
officers and employees relating to any issues plead or which
should have been plead during this case. As a part of this
agreement, the City agrees to execute a dismissal of all of
their claims against the Ackermans relating to any issues
plead or which should have been plead during this case. Said
dismissals shall be with prejudice.
8. The Ackermans agree to have their septic system inspected
every two years in May or June of the inspection year. The
inspector shall be If
is unable to perform the inspection for any reason, the City
and the Ackermans shall agree on an inspector. If no
agreement can be reached, the City and the Ackermans agree to
each submit a list of three inspectors to the Wright County
Judge who may have jurisdiction over this case at such time
and the Judge shall appoint the inspector. Said appointment
shall be binding upon the City and the Ackermans. Any
inspector agreed by the parties or appointed by the Judge must
be a MPCA certified inspector. The cost of the bi-annual
inspection shall be borne by the Ackermans.
9. The City retains the right to have the agreed upon septic
inspector enter the Ackermans property at reasonable times for
an inspection at City expense. The Ackermans agree to allow
such inspections, and the City shall inform the Ackermans
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shortly before such inspections occur.
10. If the agreed upon inspector certifies that the Ackermans
septic system does not function as designed, the Ackermans
agree that they will repair the system to function as designed
or replace the septic system per the City ordinance within 90
days. If the system is not so repaired or replaced within 90
days, the Ackermans will vacate the premises until the system
is properly repaired or replaced per City ordinance.
11. All parties agree that the judgment of the agreed upon
inspector will be final and binding upon all parties.
12. This agreement is not assignable by the Ackermans to any
party.
13. Ackermans agree to have the premises inspected per this
agreement within 30 days of the execution of this document.
The next regularly scheduled inspection under paragraph 8
above shall occur in 1996, and every two years thereafter.
14. The parties agree that the Court shall retain jurisdiction to
enforce and interpret this agreement.
15. The Ackermans agree to forfeit the right to operate the puppy
sales operation on the premises if they violate the terms of
this agreement.
16. The Ackermans and the City agree that both parties have had an
opportunity to have this document reviewed by counsel, and
that both parties shall be deemed to have jointly drafted this
document should any provisions of this document require
interpretation by the Court.
17. The City shall have the right to inspect the puppy housing
facility and the outdoor runs (if used) once per month with a
minimum of 24 hours notice to the Ackermans, and the City
shall have the right to inspect the premises once a year with
no notice to the Ackermans. The Ackermans agree to allow
these inspections without interference.
18. The Ackermans shall, by August 1, 1994, have purchased and
have on the premises 11 additional wire puppy cages
(substantially similar to the wire puppy cages currently in
the puppy facility) and all marlite necessary to adequately
cover the floor of the puppy facility, the walls next to the
puppy cages, under all puppy cages and the bottoms of any
remaining cages.
19. The Ackermans shall be allowed to keep their existing wooden
cages (provided they are sealed with marlite) to the extent
they are needed to care for the female dogs with puppies that
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are described in paragraph 1 above. After November 1, 1994,
the Ackermans shall have no more than 2 such wooden cages on
the premises, and all it puppy wire puppy cages described in
paragraph 18 above shall be installed in the puppy facility.
20. The Ackermans may fill existing outdoor runs with pea rock for
use as a temporary exercise facility (not as a housing
facility) for puppies, provided the rock is maintained in a
clean and sanitary fashion.
21. The Ackermans, at any given time, will keep no more than the
following number of puppies (classified by type) in the wire
cages described above:
a. For Shih Tzu, Bichon Frise, Cocker Spaniel, Yorkshie
Terrior, Maltese, Cairn Terrior, Scotties, West Highland
Terriors and Silky Terrior varieties, no more than three
puppies per cage.
b. For Wheaton Terriors, no more than two puppies per cage.
If the Ackermans obtain additional varieties of puppies other
than those listed above, the City and the Ackermans shall
agree on the maximum number of puppies per cage based upon the
average length and height of a 12 week old puppy of the
additional variety.
22. This agreement shall not run with the land, and the non-
conforming, pre-existing use described above shall cease when
the Ackermans dispose of their ownership interest in the
premises.
Dated:
CITY OF ALBERTVILLE
Mayor
Cler
RALPH ACKERMAN
HELEN ACKERMAN
The foregoing instrument was acknowledged before me this
day of , 1994, by Michael Potter as
Mayor of the City of Albertville, a Minnesota municipal
corporation, on behalf of the city and pursuant to the authority of
the City Council.
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Notary Public
STATE OF MINNESOTA )
ss.
COUNTY OF WRIGHT )
The foregoing instrument was acknowledged before me this
day of , 1994, by Linda Houghton, as
Clerk of the City of Albertville, a Minnesota municipal
corporation, on behalf of the city and pursuant to the authority of
the City Council.
STATE OF MINNESOTA
COUNTY OF WRIGHT
The foregoing
day of
Ralph Ackerman.
Notary Public
ss.
instrument was acknowledged before me this
, 1994, by Helen Ackerman and
Notary Public
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