United States District Court
District of Minnesota
MEMORANDUM OF FACT AND
LAW SUPPORTING APPELLANT’S
City of St. Paul, St. Paul Water Board;et al )-Relatees-Respondents
v. NOTICE OF REMOVAL
Mrs. Sharon Anderson; Relator-Removant REMOVAL TO FEDERAL COURT
AND PETITION FOR IMMEDIATE,
TEMPORARY INJUNCTIVE RELIEF
BARRING TRIAL VIA
Appellant ) ADMINISTRATIVE HEARING
Tickets,Warrants,Bills of Lading, RICO Pattern609.903, Minnesota Statutes 2006
Administrative Court: no file Jurisdiction/Authority Challenge
St. Paul City Council Ratifications date,time,due process
Federal Court File:___________
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MEMORANDUM OF FACT AND LAW
EXTENDED HISTORY OF MOTIVATION FOR HARASSMENT, CHRONOLOGY
LONG TERM HISTORY OF DEFAMATION AND HARASSMENT
The Appellant has been a political candidate in St. Paul and Minnesota for over twenty years. Appellant has also been involved in several instances of litigation which resulted in loss of Appellant’s real property, owned in St. Paul,Aitkin,Itasca and Crow-Wing, Minnesota. This agency is motivated to harass Affiant because Affiant has been critical of St. Paul government and a whistleblower in the past.
HISTORY OF THIS CASE FOR REMOVAL
This action began by the St. Paul water board threatening to disconnect Appellant’s water services, possibly because the exterior meter is apparently not working, and the said agency refuses to replace/repair that meter from the outside.
Appellant has no outstanding water bills and has phoned in a current water meter reading from the inside meter, which works, to the Water Board, and sent has digital photos of the water meter to verify, see:
http://www.angelfire.com/mn3/andersonadvocates/2006water/water.html
http://www.sharonanderson.org/ http://www.sharon4anderson.org/
This action by said agency has to be speculated upon because the agency refuses to give adequate or clear statement of their reasons for the purposes of an appealed scheduled for 4/18/2003, and in doing so denies Appellant the appearance of due process, and is abusing it’s authority to violate Appellant’s privacy rights, wantonly.
ISSUES OF FACT
There is no know fault inside Appellant’s home which would justify that agency’s coming into Appellant’s home, and the agency refuses to give adequate or believable grounds fro such a entry.
The agency’s powers are subordinate to the Minnesota and US constitution and Minnesota law defines; for legal purposes in determinations of fact and law; acceptable interpretations of words in statutes:
645. Statutes, Construction
Minnesota Statutes, ß645.08, Canons of Construction: In construing the statutes of this state, the following canons of interpretations are to govern, unless their observance would involve a construction inconsistent with the manifest intent of the legislature, or repugnant to the context of the statute:
(1) words and phrases are construed according to ... their common and approved usage; but technical words and phrases and others as have acquired a special meaning; or are defined in this chapter, are construed according to such special meaning or their definition;...
(2) General words are construed to be restricted to their meanings by proceeding particular words;...
Therefore, clearly the basic, long standing cannons of law and state statutory definitions would have to be reviled and violated in order to proceed to trial to invoke the claim that a code violation of some form has been committed. City ordinances would have to stand apart from the rest of the law and a new and foreign standard of law and common understanding of language would have to be created for the criminal charges at issue in the above entitled action to survive and for this case to proceed to trial. There clearly are no genuine issues of fact to be determined, at a hearing, as the agency refuses to state these issues in an appeal su