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<br />STATE OF MINNESOTA <br />COUNTY OF SHERBURNE <br />Lorraine White, Trustee for the <br />Lorraine M. White Trust, and <br />Wapiti Park Campgrounds, Inc., <br />A Minnesota Corporation, <br />Plaintiffs, <br />v. <br />City of Elk River, <br />DISTRICT COURT <br />TENTH JUDICIAL DISTRICT <br />Case Type: Zoning <br />File No.: Not Yet Assigned <br />Judge: Not Yet Assigned <br />MEMORANDUM IN SUPPORT OF <br />WAPITI PARK CAMPGROUNDS <br />Defendant. <br />INTRODUCTION <br />Applicants Lorraine White, Trustee for the Lorraine M. White Trust and Wapiti Park <br />Campgrounds, Inc. (collectively referred to as "Applicants") submit this memorandum in <br />response to the actions taken by the City of Elk River ("City") to: <br />(1) deny the renewal of Applicants' 2000 Interim Use Permit ("2000 IUP"); <br />(2) deny the renewal of Applicants' Liquor Licenses; <br />(3) deny the rene~,val of Applicants' Consumption and I~isp1_ay Permit; and <br />(4) revoke the 1984 Conditional Use Permit ("1984 CUP") <br />Since its inception in 1976, Wapiti Park Campgrounds, Inc. ("Wapiti") has always, even <br />prior to the adoption of the City of Elk River's ("City") City Code ("Code"), operated as a <br />recreational campground. Upon the implementation of the Code in 1980, campgrounds were <br />neither a permitted nor conditional use in the zone where Wapiti is located. As a result, Wapiti <br />became a legal, nonconforming use. The City amended its Code in 1983 to allow campgrounds <br />