Amended Federal Case
May 18th, 2022
The Federal complaint has now been amended.
Economic Impact Study
March 18th, 2022
Real Estate - Property Value Impact Report
Properties Within 1 Mile Radius of Proposed Slaughterhouse
March 18th, 2022
Map Illustrating Proximity of Plaintiffs to Slaughterhouse
Properties Within 1/3 Mile Radius of Proposed Slaughterhouse
March 18th, 2022
Map Illustrating Proximity of Plaintiffs to Slaughterhouse
Circuit Court Case Update
20-CV-7031
April 20th, 2022
Brief in Support of Summary Judgment and Sanctions
Brief in Support of Summary Judgment and Sanctions
Federal Case Filing
April 2nd, 2022
FCA Federal Challenge to Slaughterhouse SUP and TID6
New Exhibits
March 11th, 2022
Supporting Exhibits
2/17/ 2022 Plan Commission Meeting
22-CV-523 : Exhibit A- Critique of Hanneman Economic Paper
22-CV-523 : Exhibit B- Property Values Near a Slaughterhouse
20-CV-7031 : Exhibits C- Concentric Circles of Distance From the Slaughterhouse
20-CV-7031 : Exhibits D- Jerry Bussen
20-CV-7031 : Exhibit E- Jerry Bussen
20-CV-7031 : Exhibit F- Fire Chief Concerns Ammonia and Response Times
20-CV-7031 : Exhibit G- No Restrictions on Strauss
20-CV-7031 : Olson Appears to Work With Or For SR Mills and Strauss
20-CV-7031 : Exhibit I
Documents Filed
BRIEF REGARDING THE CITY OF FRANKLIN’S
MOTION TO CORRECT THE RECORD
March 11th, 2022
In response to the City and its counsel’s Motion to Correct the record and accompanying Affidavit, Doc Nos. 193, 194, Plaintiffs provide the following response and request for relief:
Motion for Correction of the Record filed by the City of Franklin: DECLINED
February 9th, 2022
City of Franklin Atty Bitar was court ordered to correct the record. His motion to correct the record was denied and he must now file a motion and motion for hearing date to do so.
FCA Files New Open Records Case: FCA v. City of Franklin 22-CV-523
January 26th, 2022
FCA has filed a new case against the City of Franklin. Exhibits can be found at the bottom of the page. FCA v. City of Franklin 22-CV-523
ORDER MOTION FOR RECONSIDERATION CORRECTION OF THE RECORD AMENDED REMAND ORDER FOR FURTHER PROCEEDINGS
January 25th, 2022
A hearing was held via zoom on January 10, 2022 before the Hon. Hannah C. Dugan on Defendants Motion for Reconsideration. Appearances were made by Plaintiffs by the Law Offices of Joseph R. Cincotta by Joseph R. Cincotta, Defendant City of Franklin by Municipal Law & Litigation Group, S.C. by Remzy D. Bitar, and Intervenor Strauss Brands, LLC by Stafford Rosenbaum, LLP by Rick A. Manthe.
Affidavit of City of Franklin Attorney Remzy D. Bitar
January 21st, 2022
Affidavit of City of Franklin Attorney Remzy D. Bitar
CITY OF FRANKLIN’S NOTICE OF MOTION AND MOTION TO CORRECT THE RECORD
January 21st, 2022
CONCLUSION For the foregoing reasons, the City of Franklin respectfully moves to withdraw the aforementioned statement in its Motion for Reconsideration that the remand related to supplementation of the two records because, instead, said Motion should have reflected that the court’s order for remand concerned the entire matter. Dated this 21st day of January, 2022.
Wisconsin Court of Appeals Denies City of Franklin's Request to Appeal
Jan 5, 2022
City of Franklin's Appeal Denied
Today Was a Game Changer!
November 16th, 2021
Earlier today the Circuit Court overseeing the case against the proposed Strauss Brands Slaughterhouse and the City of Franklin Ordered a new hearing on the project. The Court retained jurisdiction but remanded the matter back to the City Common Council based on the Court's concerns that there was lack of adequate due process provided to the citizens including those opposing the project during the initial hearing process last fall. The hearing is to include a full review of the Slaughterhouse application. The Plaintiffs are very gratified that the Court is allowing for transparency and for the full facts about all aspects of the project and the process to come out in a public forum.
Joseph R. Cincotta
Law Offices of Joseph R. Cincotta, LLC
Approval of Extension of Brief - 8-26-2021
June 9, 2019
Approval was granted for extension of brief.
Affidavit of D. Sorensen - Aug 16th
August 16th, 2021
SUPPLEMENTAL AFFIDAVIT OF DAVID SORENSEN IN SUPPORT OF MOTION TO SUPPLEMENT THE RECORD
Reply Brief in Support of Motion to Complete the Record
August 16th, 2021
REPLY BRIEF IN SUPPORT OF MOTION TO COMPLETE THE RECORD
City of Franklin Brief Opposing Completing the Record
June 9, 2019
CITY OF FRANKLIN’S RESPONSE BRIEF TO PLAINTIFFS’MOTION TO COMPLETE THE RECORD AND FOR AN EXTENSION OF THE BRIEFING SCHEDULE
Affidavit of D. Sorensen Explaining Exhibits
July 16, 2021
Explanation of Exhibits provided
FCA's Brief on Merits
Jul 16, 2021
BRIEF IN SUPPORT OF PLAINTIFFS’CLAIM FOR REVERSAL OF GRANT OF SPECIAL USE PERMIT
AFFIDAVIT OF DAVID SORENSEN IN SUPPORT OF MOTION TO SUPPLEMENT THE RECORD
July 4th, 2021
AFFIDAVIT OF DAVID SORENSEN IN SUPPORT OF MOTION TO SUPPLEMENT THE RECORD
Notice of Motion to Complete the Record
July 3rd, 2021
NOTICE OF MOTION AND MOTION TO COMPLETE THE RECORD AND FOR AN EXTENSION OF THE BRIEFING SCHEDULE
Another Attempt to Silence Citizens
December 28th, 2020
Citizens Censored at Common Council Meeting on Ethics Board
FCA Legal Challenge Updated
December 24th, 2020
FCA has supplemented its case
Ethics Board on 12/15/20 Common Council Agenda
December 15th, 2020
I'm a paragraph. Click here to add your own text and edit me. It’s easy. Just click “Edit Text” or double click me to add your own content and make changes to the font. I’m a great place for you to tell a story and let your users know a little more about you.
Franklin Community Advocates, Inc. Files Legal Challenge
December 1st, 2020
Franklin Community Advocates has filed a legal challenge to contest the validity of the Special Use Permit approved by the City of Franklin for Strauss Brands.
Citizens that demanded the slaughterhouse’s special use not be approved and worked to inform fellow neighbors about the proposal have come together to form an official community group, Franklin Community Advocates (FCA). Marcelino Rivera, Executive Director of FCA created the online petition which now has over 5000 signatures opposing the Strauss proposal in Franklin. The official summons and complaint list five points of contention with the application and approval; Lack of substantial evidence, Interference with adjacent developments, Contrary to applicable zoning, Inconsistent with Comprehensive Plan (Violation of Wis. Stats. 66.1001), and Violation of Due Process – Risk of Bias.
Exhibits
22-CV-523 : Exhibit A
22-CV-523 : Exhibit B
20-CV-7031 : Exhibits A-H
20-CV-7031 : Exhibits U-W
20-CV-7031 : Exhibits X-Z
