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

Filing 181

OBJECTION re 179 Notice of Hearing on Motion, 178 Joint MOTION to Approve Consent Judgment and Permanent Injunction to Improperly Scheduled Hearing date filed by Christopher D. Jacobsen, Robert J. Bergstrom, Craig A. Zenobian, Shane M. Steffensen. (Ramsay, Charles)

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UNITED STATES DISTRICT COURT DISTRICT OF MINNESOTA _________________________________ State of Minnesota, by Michael Campion, its Commissioner of Public Safety, Court File No. 0:08-cv-00603-DWF-AJB Plaintiff, v. CMI of Kentucky, Inc., A Kentucky Corporation, Defendant, and Robert J. Bergstrom, Craig A. Zenobian, Shane M. Steffensen and Christopher D. Jacobsen, Plaintiffs-Intervenor. _________________________________ TO: TO THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF MINNESOTA, PLAINITFF STATE OF MINNESOTA AND ITS ATTORNEYS AND DEFENDANT AND ITS ATTORNEYS: PLEASE TAKE NOTICE: That Plaintiffs-Intervenor object to the June 11, 2009 scheduled hearing on Plaintiff's and Defendant's Joint Motion for Consent Judgment and Permanent Injunction. The said June 11, 2009 hearing, the notice of which was submitted on June 1, 2009, does not comply with Local Rule 7.1 of the Local Rules for the United States Minnesota District Court. Said scheduling significantly cuts short the time for both Plaintiffs-Intervenor and the amicus who previously submitted briefing on the prior proposed consent judgment of the full 1 PLAINTIFFS-INTERVENOR'S OBJECTION TO THE SCHEDULING OUT OF TIME THE HEARING ON PLAINTIFF AND DEFENDANT'S PROPOSED CONSENT JUDGMENT AND PERMANENT INJUNCTION time the Rules contemplate should be afforded them to fully address the proposed settlement. Plaintiffs-Intervenor respectfully request that the hearing on this matter be scheduled in accordance with the Rules. RAMSAY & ASSOCIATES, P.L.L.C. Dated: June 1, 2009 /s/ Charles A. Ramsay Charles A. Ramsay, ID No. 260277 2780 Snelling Avenue North, #330 Roseville, Minnesota 55113 651-604-0000 /s/ Daniel J. Koewler Daniel J. Koewler, ID No. 388460 2780 Snelling Avenue North, #330 Roseville, Minnesota 55113 651-604-0000 GORES LAW OFFICE Dated: June 1, 2009 /s/ John J. Gores John J. Gores, ID No. 228928 7091 Highway 65 NE, Suite 201 Fridley, Minnesota 55432 763-571-4777 Attorneys for Plaintiffs-Intervenors Dated: June 1, 2009 2

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