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STATE OF INDIANA, ST. JOSEPH COUNTY <br />IN THE ST. JOSEPH SUPERIOR COURT <br />MISHAWAKA DIVISION <br />THE HISTORIC PRESERVATION <br />COMMISSION OF SOUTH BEND AND <br />ST. JOSEPH COUNTY, <br />Plaintif f , <br />M <br />CAUSE NO. 71D07 -9209 -CP - <br />WILLIAM F. MORAN, <br />1071 Riverside Drive, <br />South Bend, Indiana 46616, <br />Defendant. <br />COMPLAINT .FOR INJUNCTIVE AND EQUITABLE RELIEF <br />1) The Historic Preservation Commission of South Bend and <br />St. Joseph County, Indiana, is a governmental subdivision of both the <br />City of South Bend and the County of St. Joseph which are corporations <br />duly organized under the laws of the State of Indiana; the Historic <br />Preservation Commission was created pursuant to Title 36, Article 7, <br />of the Indiana Code, and is empowered to designate and regulate <br />Historic Preservation Districts. <br />2) Defendant William F. Moran is the owner of realty located <br />at 1071 Riverside Drive, South Bend, St. Joseph County, Indiana, <br />having the following legal description: <br />A lot or parcel of land 30 feet in width taken off <br />of and from the Westerly side of Lot Numbered <br />Eighty-one (81) and another lot or parcel of land <br />10 feet in width taken off of and from the Easterly <br />side of Lot Numbered Eighty-two (82) all as shown <br />on the recorded Third Plat of Shetterly Place <br />Addition to the City of South Bend, recorded <br />October 6, 1891 in the Office of the Recorder of <br />St. Joseph County, Indiana, in Plat Book 5, page <br />60. <br />