Minnesota, State of v. CMI of Kentucky, Inc.

Filing 105

Minnesota, State of v. CMI of Kentucky, Inc.

Doc. 105

UNITED STATES DISTRICT COURT DISTRICT OF MINNESOTA State of Minnesota, by Michael Campion, its Commissioner of Public Safety, Plaintiff, v. CMI of Kentucky, Inc., a Kentucky corporation, Defendant, and Robert J. Bergstrom, Craig A. Zenobian, Shane M. Steffensen, and Christopher D. Jacobsen, Plaintiff-Intervenors. TO: Plaintiff State of Minnesota by Michael Campion, its Commissioner of Public Safety and its and his Attorneys, LORI SWANSON, ATTORNEY GENERAL STATE OF MINNESOTA, Emerald A. Gratz, 445 Minnesota Street, Suite 1800, St. Paul, Minnesota, and Plaintiff-Intervenors Robert J. Bergstrom, Craig A. Zenobian, Shane M. Steffensen, and Christopher D. Jacobsen, and their attorneys, RAMSAY & ASSOCIATES, Charles A. Ramsay and Daniel J. Koewler, 450 Rosedale Towers, 1700 West Highway 36, Roseville, Minnesota, and GORES LAW OFFICE, John J. Gores, 7091 Highway 65 N.E., Suite 201, Fridley, Minnesota. Please take notice that on May 22, 2009, at 9:00 a.m., in Courtroom 7C, Warren E. Burger Federal Building and U.S. Courthouse, 316 North Robert Street, St. Paul, Minnesota, before the Honorable Donovan W. Frank, District Court Judge, Defendant CMI of Kentucky, Inc. will move the Court for Partial Summary Judgment or, in the NOTICE OF DEFENDANT'S MOTION FOR PARTIAL SUMMARY JUDGMENT OR, IN THE ALTERNATIVE, FOR JUDGMENT ON THE PLEADINGS File No. 08-CV-603 (DWF/AJB)

Dockets.Justia.com

alternative, for Judgment on the Pleadings, on Counts II, III and IV of the State's Complaint, Count I of Plaintiff-Intervenors' Complaint-in-Intervention, and for Summary Judgment on Count II of Defendant's Counterclaim. Defendant's motion is based upon the file, record, pleadings in the case, arguments of counsel, and the memoranda of law to be filed in the ordinary course.
Respectfully Submitted,

Dated: February 27, 2009

WINTHROP & WEINSTINE, P.A. s/William A. McNab David M. Aafedt, MN #27561X William A. McNab, MN #312071 WINTHROP & WEINSTINE, P.A. 225 South Sixth Street, Ste. 3500 Minneapolis, Minnesota 55402-4629 Tel: [phone] Fax: [phone] [e-mail] [e-mail] ATTORNEYS FOR DEFENDANT CMI OF KENTUCKY, INC.

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