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1 <br />2 <br />3 <br />4 <br />5 <br />6 <br />7 <br />8 <br />9 <br />10 <br />. 11 <br />12 <br />13 <br />14 <br />15 <br />16 <br />17 <br />18 <br />19 <br />20 <br />21' <br />22 <br />23 <br />24 <br />25 !, <br />~uwG 26 <br />GARY <br />RWNICK PC <br />101 E BROADWAY <br />SUfTE 400 <br />EUGENE, OR 97401 <br />Plans (541)495.0220 <br />Fax (541)698.6594 <br />an appraisal to defendant Jenova Land Company on or about June 12, 2002. <br />16. <br />The true value and estimated just compensation for the acquisition being appropriated <br />by plaintiff and the damages, if any, resulting from the appropriation thereof, is the. sum of <br />$1,570,000.00 (One Million Five Hundred Seventy Thousand Dollars), and City has offered <br />to purchase the property described in paragraph 3 hereof for $1,570,000.00 (One Million <br />Five Hundred Seventy Thousand Dollars). <br />17. <br />The City has been unable to reach agreement with defendant Jenova Land Company, <br />with respect to the compensation to be paid for the acquisition described in paragraph 3 and <br />therefore prosecutes this action. <br />WHEREFORE, the Cityprays that an assessment be made by a jury impaneled in this <br />action to determine the compensation to be paid for -the acquisition herein sought to be <br />condemned and appropriated, and that upon payment into the court of the compensation <br />assessed by a jury, a judgment be given vesting in the City the acquisition described in <br />paragraph 3 hereof. <br />DATED this 26~' day of July, 2002. <br />I~[ARRANG LONG GARY RUDNICK P.C. <br />By: <br />. / Of Attorneys for Plaintiff <br />Trial Attorney: Jens Schmidt <br />OSB #84341 <br />Page 4 PLAINTIFF'S COMPLAINT <br /> <br />