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

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Properties Within 1 Mile Radius of Proposed Slaughterhouse

March 18th, 2022

 

Map Illustrating Proximity of Plaintiffs to Slaughterhouse

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Properties Within 1/3 Mile Radius of Proposed Slaughterhouse

March 18th, 2022

Map Illustrating Proximity of Plaintiffs to Slaughterhouse

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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

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Federal Case Filing

April 2nd, 2022

FCA Federal Challenge to Slaughterhouse SUP and TID6

 

New Exhibits

March 11th, 2022

 
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22-CV-7031: Exhibit S - Strauss Letter

Supporting Exhibits

2/17/ 2022 Plan Commission Meeting

 
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22-CV-523 : Exhibit A- Critique of Hanneman Economic Paper

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22-CV-523 : Exhibit B- Property Values Near a Slaughterhouse

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20-CV-7031 : Exhibits C- Concentric Circles of Distance From the Slaughterhouse

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20-CV-7031 : Exhibits D- Jerry Bussen

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20-CV-7031 : Exhibit E- Jerry Bussen

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20-CV-7031 : Exhibit F- Fire Chief Concerns Ammonia and Response Times

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20-CV-7031 : Exhibit G- No Restrictions on Strauss

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20-CV-7031 : Olson Appears to Work With Or For SR Mills and Strauss

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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:

Exhibit S.

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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.

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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

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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.

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Affidavit of City of Franklin Attorney Remzy D. Bitar

January 21st, 2022

Affidavit of City of Franklin Attorney Remzy D. Bitar

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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.

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Wisconsin Court of Appeals Denies City of Franklin's Request to Appeal

Jan 5, 2022

City of Franklin's Appeal Denied

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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

Judge Gavel

Approval of Extension of Brief - 8-26-2021

June 9, 2019

Approval was granted for extension of brief.

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Affidavit of D. Sorensen - Aug 16th

August 16th, 2021

SUPPLEMENTAL AFFIDAVIT OF DAVID SORENSEN IN SUPPORT OF MOTION TO SUPPLEMENT THE RECORD

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Reply Brief in Support of Motion to Complete the Record

August 16th, 2021

REPLY BRIEF IN SUPPORT OF MOTION TO COMPLETE THE RECORD

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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

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Affidavit of D. Sorensen Explaining Exhibits

July 16, 2021

Explanation of Exhibits provided

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FCA's Brief on Merits

Jul 16, 2021

BRIEF IN SUPPORT OF PLAINTIFFS’CLAIM FOR REVERSAL OF GRANT OF SPECIAL USE PERMIT

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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

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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

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Another Attempt to Silence Citizens

December 28th, 2020

Citizens Censored at Common Council Meeting on Ethics Board

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FCA Legal Challenge Updated

December 24th, 2020

FCA has supplemented its case

Courthouse

Ethics Board on 12/15/20  Common Council Agenda

December 15th, 2020

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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.

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Exhibits

 
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22-CV-523 : Exhibit A

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22-CV-523 : Exhibit B

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20-CV-7031 : Exhibits A-H

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20-CV-7031 : Exhibits U-W

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20-CV-7031 : Exhibits X-Z

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20-CV-7031 : Exhibits AA-GG