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

Filing 178

Joint MOTION to Approve Consent Judgment and Permanent Injunction by Minnesota, State of, CMI of Kentucky, Inc. (McNab, William)

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Minnesota, State of v. CMI of Kentucky, Inc. Doc. 178 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. JOINT MOTION FOR ENTRY OF CONSENT JUDGMENT AND PERMANENT INJUNCTION File No. 08-CV-603 (DWF/AJB) Plaintiff State of Minnesota, by Michael Campion, its Commissioner of Public Safety, and Defendant CMI of Kentucky, Inc., hereby jointly move the Court for the Entry of the Consent Judgment and Permanent Injunction filed electronically with the Court on June 1, 2009, as Docket No. 177. This Joint Motion is based upon the file, record, pleadings and memoranda of law filed in the case, and the arguments presented by counsel. Dockets.Justia.com Respectfully Submitted, Dated: June 1, 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: (612) 604-6400 Fax: (612) 604-6800 daafedt@winthrop.com wmcnab@winthrop.com ATTORNEYS FOR DEFENDANT CMI OF KENTUCKY, INC. Dated: June 1, 2009 _ LORI SWANSON Attorney General State of Minnesota s/Alan I. Gilbert ALAN I. GILBERT Solicitor General Atty. Reg. No. 0034678 EMERALD GRATZ Assistant Attorney General Atty. Reg. No. 0345829 445 Minnesota Street, Suite 1800 St. Paul, Minnesota 55101-2134 (651) 296-2281 (Voice) (651) 282-2525 (TTY) Al.Gilbert@state.mn.us Emerald.Gratz@state.mn.us ATTORNEYS FOR PLAINTIFF STATE OF MINNESOTA 4528136v1 -2-

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