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responsible for the safe and proper placement of the utility pole in relation to the <br />roadway, and for ensuring the safe and proper condition, construction, inspection, <br />replacement, restoration, repair and maintenance of the subject pole and surrounding <br />area. <br />VII. <br />That, based upon information and belief, Defendant Connexus Energy <br />(hereinafter "Connexus") is a Minnesota Corporation which maintains its principal <br />headquarters and place of business at 14601 Ramsey Boulevard, Ramsey, Minnesota <br />55303, and which is the successor to or which was formerly known as Anoka Electric <br />Cooperative. <br />VIII. <br />That, based upon information and belief, Connexus determined the placement of <br />the subject utility pole prior to the date on which the pole was acquired by Elk River, and <br />was responsible for the safe and proper placement of the utility pole in relation to the <br />roadway, and for ensuring the safe and proper condition, construction, inspection, <br />replacement, restoration, repair and maintenance of the subject pole and surrounding <br />area. <br />IX. <br />That Defendant John Doe is a corporation, municipal corporation, or other entity <br />that is presently unknown to Plaintiff which was responsible for the placement of the <br />subject utility pole, or which was responsible to safely and properly design the highway, <br />utilize safe and proper guards and barricades, traffic signals, markings and signage, or <br />3 <br />