Khosrow Rahimi v. City of Sheridan, Oregon, et al.
1. Sole Reliance on Statute of limitations: Why did the defendants solely rely on the statute of
limitations as their claim against me? It appears that the defendants have used the expiration
of the statute of limitations as their primary argument to dismiss my case. I question the
validity and fairness of this claim, considering that my attempts to seek assistant, and
compensation from flic City and State were met with delays, failure to help, and misleading
actions. I seek clarification on whether the defendants' heavy reliance on the statute of
limitations adequately addresses the underlying issues of misconduct and violation of my
rights.
2. Violation of Civil, Constitutional, and Property Rights: How were my civil rights,
constitutional rights, and property rights violated in this case? I believe that the defendants'
actions, including tire re-designation of my land as wetland and later changing it back to light
industrial, have infringed upon my fundamental righto. I seek clarification and redress for
these violations.
3. Lack of Environmental Justification: Why did tire defendants not provide any environmental
justification for changing the land back to light industrial, favoring the new owner? I request
an explanation for the sadden reversal of the land's designation, as it appears to have been
detrimental to my interests while benefiting Others. Understanding the reasons behind this
decision is crucial to establishing the fairness and legitimacy of the actions taken.
4. Absence of Assistance from City & State: Why did the City and State fail to provide me, as a
taxpayer seeking help, with the necessary support and guidance when I reached out to them
after my land was taken from me? I entrusted them to address my concerns and provide
assistance in navigating the situation. Their lack of intervention and misleading actions have
exacerbated my predicament, and I seek an explanation for their failure to fulfill their
responsibilities.
5. Examination of the Case and Loss of Property: Can we thoroughly examine tire
circumstances surrounding the loss of my land and investment? I request a comprehensive
evaluation of the case to d line tire factors that led to the adverse outcome.
Understanding tire reasons behind the loss of my property and investment is crucial in
seeking justice and appropriate compensation for the damages incurred.
6. Fairness and Impact on a Taxpaying Citizen: Is it fair to subject a taxpaying citizen to such
treatment, resulting in the loss of property and homelessness? I urge the court to consider the
profound impact tins case has had on my life, transforming me from a successful landowner
to a homeless individual. Evaluating the fairness of these cir
ensuring equal treatment under die law and protecting the rights of taxpayers.
7. Failure to Provide Compensation within the Statute of limitations: Why did the City and
State fail to provide the compensation I deserved when this situation unfolded, especially
considering that we were still within the applicable statute of limitations? I seek an
explanation for their inaction and the subsequent use of the statute of limitations as a basis to
dismiss my case. Understanding the reasons behind their failure to fulfill their obligations is
crucial to addressing the injustice I have faced.
Whether the government's failure to provide just compensation within the statute of limitations for a taking of private property violates the Fifth Amendment's Takings Clause