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3:14-cv-00057 #51

3:14-cv-00057 #51

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Published by Equality Case Files
Doc 51 - MEMORANDUM in Support of Parties' Joint MOTION for Extension of Time to File Response/Reply
Doc 51 - MEMORANDUM in Support of Parties' Joint MOTION for Extension of Time to File Response/Reply

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Published by: Equality Case Files on Aug 16, 2014
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09/04/2014

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UNITED STATES DISTRICT COURT DISTRICT OF NORTH DAKOTA Ron Ramsay and Peter Vandervort; ) Celeste and Amber Carlson Allebach; ) Brock Dahl and Austin Lang; Michelle ) Harmon and Joy Haarstick; Bernie ) Erickson and David Hamilton; Matthew ) Lee Elmore and Beau Thomas Downey; ) and Stephanie and Siana Bock, ) ) Plaintiffs, )
JOINT MEMORANDUM IN SUPPORT OF
 )
MOTION FOR EXTENSION OF TIME
v. ) )
 Case No. 3:14-CV-57
 Jack Dalrymple, in his official capacity ) as Governor; Wayne Stenehjem, in his ) official capacity as Attorney General; ) Ryan Rauschenberger, in his official ) capacity as State Tax Commissioner; ) Terry Dwelle, in his official capacity as ) State Health Officer; and Charlotte ) Sandvik, in her official capacity as Cass ) County Treasurer, ) ) Defendants. ) .....................................................................................................................................................
INTRODUCTION
Plaintiffs filed their Complaint for Permanent Injunction and Declaratory Relief (Doc. 1) on June 6 2014. On June 10, 2014, they filed their First Amended Complaint for Permanent Injunction and Declaratory Relief (Doc. 19). Defendants Jack Dalrymple, in his official capacity as Governor, Wayne Stenehjem, in his official capacity as Attorney General, Ryan Rauschenberger, in his official capacity as Tax Commissioner, and Terry Dwelle, in his official capacity as State Health Officer (collectively “State Defendants”), filed a Motion to Dismiss on July 1, 2014 (Doc. 28). Plaintiffs filed Plaintiffs’ Motion for Summary Judgment and a consolidated memorandum in support of their motion and opposing State Defendants’ Motion to Dismiss on July 22, 2014 (Docs. 41, 42).
Case 3:14-cv-00057-RRE-KKK Document 51 Filed 08/08/14 Page 1 of 4
 
 
2 The Parties jointly request that Defendants have until August 22, 2014 to file and serve their response to Plaintiffs’ Motion for Summary Judgment (Doc. 42).
ARGUMENT
Absent an extension, Defendants have 21 days to respond to Plaintiff’s Motion for Summary Judgment. D.N.D. Civ. L. R. 7.1(A)(1). Due to counsel for State Defendants’ professional and personal schedule, including the unplanned need to attend the out-of-state funeral of his sister-in-law, the Parties request that Defendants be granted until August 22, 2014 to file and serve their response to Plaintiffs’ Motion for Summary Judgment. Plaintiffs agree they will not be prejudiced by the requested extension.
CONCLUSION
The Parties jointly request that Defendants be granted until August 22, 2014 to file and serve their response to Plaintiffs’ Motion for Summary Judgment (Doc. 42). Dated this 8
th
 day of August, 2014. State of North Dakota Wayne Stenehjem Attorney General By: /s/ Douglas A. Bahr
 
Douglas A. Bahr Solicitor General State Bar ID No. 04940 Office of Attorney General 500 North 9
th
 Street Bismarck, ND 58501-4509 Telephone (701) 328-3640 Facsimile (701) 328-4300 Email dbahr@nd.gov Attorneys for Defendants Jack Dalrymple, in his official capacity as Governor, Wayne Stenehjem, in his official capacity as Attorney General, Ryan Rauschenberger, in his official capacity as Tax Commissioner, and Terry Dwelle, in his official capacity as State Health Officer.
Case 3:14-cv-00057-RRE-KKK Document 51 Filed 08/08/14 Page 2 of 4
 
 
3 Dated this 8
th
 day of August, 2014. By: /s/ Scott K. Porsborg Scott K. Porsborg Cass County Special Assistant State’s Attorneys State Bar ID No. 04904 122 East Broadway Avenue P.O. Box 460 Bismarck, ND 58502-0460 Telephone (701) 258-0630 Email sporsborg@smithbakke.com Attorneys for Defendant, Charlotte Sandvik, in her official capacity as Cass County Treasurer. Dated this 8
th
 day of August, 2014. MADIA LAW LLC By: /s/ Joshua A. Newville
 
Joshua A. Newville Attorney at Law Admitted
pro hac vice
345 Union Plaza 333 Washington Avenue North Minneapolis, Minnesota 55401 Telephone (612) 349-2743 Facsimile (612) 235-3357 Email joshuanewville@madialaw.com Attorneys for Plaintiffs.
 
Case 3:14-cv-00057-RRE-KKK Document 51 Filed 08/08/14 Page 3 of 4

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