Almer v. Peanut Corporation of America

Filing 101

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Almer v. Peanut Corporation of America Doc. 101 UNITED STATES DISTRICT COURT DISTRICT OF MINNESOTA _____________________________________________________________________________ Pau lett e Pahnke, individually and As parent and natural guardian of Brittany Newman, Alyssa Newman, and Michael Newman, minors, Plaintiff, v. Anderson Moving and Storage, Home Apartment Development, LLC, County of Houston, City of LaCrescent, John Doe, and Jim Doe, NOTICE OF MOTIONS AND MOTIONS FOR SUMMARY JUDGMENT AGAINST ANDERSON MOVING AND STORAGE AND HOME APARTMENT DEVELOPMENT, LLC Court File No. 04-1299(PAM/RLE) Defendants. _____________________________________________________________________________ TO: Defendants above named and their counsel of record. PLEASE TAKE NOTICE that on May 4, 2005, at 10:00 a.m., Plaintiff will bring a Mot ion for Summary Judgment before the Honorable Paul A. Magnuson at the United States District Court, District of Minnesota, Warren E. Burger Federal Building, 316 North Robert Street , Room 1738, St. Paul, Minnesota 55101, or as soon thereafter as the matter may be heard. Plaintiff moves for Summary Judgment against Defendants Anderson Moving and Sto rage and Home Apartment Development, LLC, as follows: 1. That Home Apartment Development, LLC violated 504B.365, Subd. 3, and Plaintiff is entitled to damages against Home Apartment Development, LLC pursuant to 504B.365, Subd 5., and 504B.231. That Anderson Moving and Storage violated 504B.365, Subd. 3, and Plaintiff is entitled to damages against Anderson Moving and Storage pursuant to 504B.365, Subd 5., and 504B.231. 2. The above Summary Judgment Motions are made pursuant to Rule 56 of the Federal Rules of Civil Procedure as there is no genuine issue as to any material fact and Plaintiff is entitled to judgment as a matter of law. Said Motions will be made upon all of the files, records and proceedings herein and upon the Memorandum of Law and Affidavits submitted therewith. Dated: March ___, 2005. _______________________________ William L. French, #131945 P.O. Box 6323 627 Woodhaven Court NE Rochester, MN 55903 Telephone: (507) 280-6136 -andJeffrey A. Hanson, #40897 Hanson Law Firm 402 S. Mantorville Ave. Kasson, MN 55944 Telephone: (507) 634-3202 Attorneys for Paulette Pahnke

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