. SKELTON

TAINTOR
8c ABBOTT

ATTORNEYS AT. LAW

 

P. L. BEAUDIN I dun. A. CHECKOWAY I BRYAN M. DENCH AMT 
JORDAN PAYNE HAY I RONALD P. LEBEL I SARAH C. MITCHELL I MICHAEL R. I NORMAN .J. 
THEODORE SMALL I BENJAMIN .J. SMITH I STEPHEN B. WADE I REBECCA S. WEBBER

May 1,2017

BY HAND DELIVERY

Michele Lumbert, Clerk
Kennebec Superior Court
Capital Judicial Center

1 Court Street, Suite 101
Augusta, ME 04330

RE: Governor Paul R. LePage v. Attorney General Janet T. Mills
Docket No.

Dear Michele:

Please ?le the enclosed Complaint for Declaratory Judgment and a completed Civil
Summary Sheet. Also enclosed please ?nd this ?rm?s check in the amount of $150.00 to cover
the ?ling fee. We will ?le the Summons once service has been made upon the Defendant.

Thank you for your assistance in this matter.

Very truly yours,

HWY ?ztn?m

ryan M. Dench
BMD/rnl
Enclosures
cc: Hon. Paul R. LePage, Governor, State of Maine (W/enc.)

Attorney General Janet T. Mills (w/enc. and Summons)

 

95 MAIN STREEF AUBURN, ME 04210 OFFICE: 207.784.3200
FAX: 207.784.3345 E-MAIL: 

STATE OF MAINE, Superior Court
Kennebec SS Docket No. CV-

PAUL R. LEPAGE,
in his capacity as Governor ofthe
State of Maine,

Plaintiff, COMPLAINT FOR DECLARATORY JUDGMENT,

JANET T. MILLS, 14 MR. 5. 5951, ETSEQ.

in her capacity as Attorney General
ofthe State ofMaine,






i
Vs. PURSUANT To THE CONSTITUTION 0F MAINE AND





Defendant. 


Plaintiff Governor Paul R. LePage complains against the Defendant, Attorney General

Janet T. Mills, seeking a declaration of the duties and authorities of the parties pursuant to

the Constitution ofMaine and their respective offices in the particular circumstances ofthis

case, and states as follows:

1. Plaintiff Paul R. LePage is the duly?elected, serving Governor of the State ofMaine,
residing in Augusta, Kennebec County, Maine.

2. Defendant Janet T. Mills is the duly-elected, serving Attorney General ofthe State of
Maine, conducting official business in offices located in Augusta, Kennebec County,
Maine.

3. As more particularly set forth below, Defendant is preventing Plaintiff from executing
the duties ofhis office according to his own good faith judgment of the interests of the
people of the State of Maine by refusing to represent the State of Maine?s interests in
litigation when requested by Plaintiff and at the same time placing impermissible and

illegal conditions on Plaintiff?s retention ofoutside counsel, the retention ofwhich is

necessary because of Defendant?s refusal to represent the Governor of the State of
Maine.

These actions by the Defendant exceed the scope of her authority and constitute a
breach ofher duties of office under the Constitution ofthe State of Maine and the
controlling statute, 5 M.R.S. 191.

Because there is a genuine controversy between the parties with respect to these
matters, and without a declaration by the Court of the respective authority and duty of
the parties, together with the entry of the appropriate order for relief, the Plaintiff
would be without any remedy, the Court has jurisdiction under 14 M.R.S. 5951, etseq.
Under the Constitution ofMaine, there are three branches ofgovernment, each with its

separate authority, as follows:

Article Ill.
Distribution of Powers.
Section 1. Powers distributed. The powers ofthis government shall
be divided into 3 distinct departments, the legislative, executive and

judicial.
Section 2. To be kept separate. No person or persons, belonging to
one ofthese departments, shall exercise any of the powers properly

belonging to either of the others, except in the cases herein expressly
directed or permitted.

Plaintiff, as Governor, has a constitutional duty to ?take care that the laws be faithfully
executed,? Me. Const. art. V, pt. 1, 12, and all executive power of the State is vested in
Plaintiff as the holder of that office. Id. at 1.

The power of the executive has always been understood to include the power to protect

public safety.

9. The Constitution of Maine creates the officer known as the Attorney General but does
not state what the Attorney General?s duties or authority are.
10. In pertinent part, the controlling (and only) statute defining the duties and authority of
the Attorney General under the Maine Constitution reads, as follows:
5 M.R.S. 191(3) Representation by Attorney General, deputies,
assistants and staff attorneys. The Attorney General or a deputy,
assistant or staff attorney shall appear for the all the courts
of the State and in those actions and proceedings before any other
tribunal when requested by the Governor All such actions and
proceedings must be prosecuted or defended by the Attorney General
or under the Attorney General?s 
B. All legal services required by those officers, boards and
commissions in matters relating to their official duties must be
rendered by the Attorney General or under the Attorney General?s
direction. The officers or agencies ofthe State may not act at the
expense of the State as counsel, nor employ private counsel except
upon prior written approval ofthe Attorney General. In all instances
where the Legislature has authorized an office or an agency of the

State to employ private counsel, the Attorney General?s written
approval is required as a condition precedent to the employment.

11. The President ofthe United States has issued two Executive orders with respect to
immigration into the United States ofAmerica. Plaintiffhas formed the executive
judgment that the President?s efforts to control immigration by the issuance of one or
more Executive orders is a measured and appropriate action to protect the people of
Maine and to enforce the laws, and therefore Plaintiffsupports the President?s action.

12. Defendant publicly opposed the first ofthe two Executive orders, number 13769, and
joined in an amicus curiae briefin opposition to it in the case of Washington v. Trump.

13. Plaintiffsought to file a countervailing briefin Washington v. Trump and requested

approval ofthe Defendant. However, by delay and obstruction, Defendant prevented

Plaintiff from timely engaging counsel to represent the people of Maine and Plaintiff
with respect to the Washington v. Trump litigation.

14. Thereafter, March 6, 2017, the President issued a second Executive order with reSpect
to control ofimmigration into the United States, temporarily suspending entry into the

United States of certain classes ofaliens. It is titled Executive Order 13780 (hereinafter,

the ?Order?).
15. On or about March 14, 2017, anticipating further litigation in the Federal courts with

reSpect to the Order, the Plaintiff wrote the Defendant stating the following with regard

to the executive position of the State of Maine:

In the exercise of my duties as Governor, have considered the effects
ofthis Order on the citizens of the State of Maine and find it to be
beneficial to the State and its citizens. I find this, among other
reasons, because until now the federal government?s administration
of immigration into the United States (over which the State has no
control) has resulted in significant societal burdens and economic
harms to our State and its citizens, including but not limited to the
following impacts:

. There have been 220 refugees resettled in Maine since October
1, 2016 alone, including 131 from terrorist havens named in the
President?s order;

0 In State Fiscal Year 2016, MaineCare spent $40,655,974 on
health care for non-citizens;
. In the same time, Maine?s General Fund spent $6,754,176 on

food stamp and cash benefits for non-citizens.

Though the federal government has seen fit to impose these burdens
on our State, it has done so without the financial support that would
be commensurate with such burdens. For these reasons I find that the
President?s Order begins a process of reviewing and controlling
immigration at the federal level that will benefit the people of Maine
and that it is in the interest of the State of Maine to support the Order.

I am also aware that the State of Hawai?i has commenced litigation in
the United States District Court for the District of Hawai?i seeking to
enjoin and invalidate the Order. This litigation will no doubt result in
an appeal before the United States Appeals Court for the 9th Circuit
(the ?litigation?). 1 have determined that it is in the interest of the

State ofMaine for the State of Maine under my direction to appear in
that litigation in support ofthe Order. In the exercise ofmy
constitutional executive authority I wish to take action on this
determination forthwith as the litigation likely will move through the
courts quickly.

16. Based on this Executive finding, the Plaintiff in the same letter made the following

requests to the Defendant:

As you know, by statute the Attorney General has a duty to appear for
the State in court proceedings when requested by the Governor.
Therefore I hereby request that you personally appear for me and the
State of Maine in the litigation, submit a briefas amicus curiae for the
State of Maine supporting the Order, and consult with me with reSpect
to the litigation including permitting me to review and comment on
the brief and any other pleadings filed in the litigation. Ifyou do not
appear personally I request that you inform of the attorney or
attorneys in your office who will do so and that I be allowed a
reasonable opportunity to approve of their representation so as to
assure the State?s interests are protected.

My requests in this regard are influenced by the fact that have
reviewed the amicus briefyou joined in the Washington v. Trump
litigation without my concurrence adopting a position challenging the
validity of the President?s previous Executive Order on this matter. I
regard your action in that case as in excess ofyour lawful authority
and contrary to your duties to the State of Maine. In addition, as you
know, your position in that litigation contradicted my own position.
You effectively prevented me from appearing in that earlier litigation
to exercise my due authority as the State?s chief executive. As
Governor and as, in effect, your client, I am entitled to have confidence
that you or your designee will provide effective representation to me
in the Hawai?i litigation consistent with my findings and the discharge
of my office. I consider that your duty by statute and your ethical duty
under the Rules of Professional Conduct.

Ifyou decline to represent me in the discharge ofmy constitutional
authority in this litigation in a manner consistent with your duties and
my rightful authority, then alternatively respectfully request that
you immediately issue written approval for me to engage private
counsel to represent me in the litigation with the cost thereofto be
borne by your office. I need this approval without delay and ask for
your reply no later than the close ofbusiness today, March 14, 2017.

Ifyou fail or refuse either to represent me as requested, or to approve
my obtaining representation through private counsel as requested in
the alternative, you will effectively prevent me from discharging my
constitutional duties and authority with reSpect to the litigation.

17. Defendant did not respond to this letter but, upon information and belief, instructed a
subordinate to do so. On March 15th, Deputy Attorney General Gardiner
responded to Plaintiff?s counsel, her letter reading in its entirety as follows:

Attorney General Mills has delegated to me the responsibility of
responding to the Governor's request, which was dated and hand
delivered to our of?ce yesterday, seeking approval to obtain counsel
to represent the Governor in a lawsuit brought by the State of Hawaii
in the United States District Court in Hawaii. The lawsuit challenges
the legality of Executive Order 13780, issued by the President on
March 6, 2017. Governor LePage has specifically requested legal
representation to file a brief as amicus curiae in support ofthe
Executive Order. A quick review of the docket entries reveals that
briefs have already been filed in the case on the State of Hawaii's
motion for a temporary restraining order, which is being heard today,
but no schedule appears to have been established yet for any future
proceedings in the case.

To the extent the Governor decides to participate in these
proceedings, he is hereby authorized to join an amicus curiae brief
prepared by another party [which would not involve additional cost
to the State], if that option is available, or, if not, to retain outside
counsel to prepare an amicus curiae briefin the case of Hawaii v.
Trump, Docket No. 1:17-cv-00050 (D. Ham), on the following
conditions: 1] the cost oflegal fees for outside counsel should be
borne by the Office of the Governor, or otherwise as appropriated by
the Legislature; and 2] a licensed attorney within the Office of the
Governor should insure that outside counsel carries adequate
malpractice insurance and holds all necessary licenses and bar
admissions to represent the Governor in this case, and should review
all the invoices submitted by outside counsel for reasonableness.

18. Plaintiffdeemed this reply unresponsive as it did not address all the points in Plaintiffs
letter, purported to shift the financial burden ofrepresentation of the State from the

Defendant?s appropriation, and imposed improper conditions on the Plaintiff?s

authority to be represented in the litigation, not merely to join in or file an amicus

curiae brief.

19. Accordingly, Plaintiffsent a further letter to the Defendant?s designee on March 

reading in pertinent part as follows:

I have received your letter dated March 15, 2017. It is not responsive
to my request to the Attorney General, as I asked under 5 M.R.S. 
191(3) for her [or an acceptable designate) to represent me in my
executive capacity. You do not address that request except by silence.
Unless you inform me otherwise, then, I must conclude that the
Attorney General refuses to perform her duties as requested.

As to the remainder ofyour letter, the Attorney General has no
authority to dictate the terms of engagement of outside counsel when
she refuses to represent me, but only the authority to give or refuse
written approval. Therefore, unless you inform me to the
contrary, I will take your letter as giving the Attorney General?s
approval without any of the limitations or conditions purportedly
imposed by your letter.

Further, I understand that there is historical precedent for the hiring
ofoutside counsel to be paid from the budget ofthe Office ofthe
Attorney General. Due to this precedent, fully expect your office to
pay the fees related to my hiring outside counsel.

20. In response, Plaintiff received from Deputy Attorney General Gardiner the following

letter dated March 20th:

This is in response to your letter ofMarch 17, 2017, in which you raise
several issues relating to the authorization to hire outside counsel to
represent you as amicus curiae in the matter ofHawaii v. Trump, as
set forth in my letter of March 15, 2017, addressed to Hancock Fenton
as your deputy general counsel. will address each issue in the order

presented.

First, the Attorney General has the authority and discretion to decline
to represent the Executive Branch in litigation, based on herjudgment
as to what is in the best interest ofthe people ofMaine. See Opinion of
thejustices, 2015 ME 27,122, 123 A. 2d 494, and Superintendent of

Insurance v. Attorney General, 558 A. 2d 1197, 1199-1200 (Me. 1989].
By authorizing outside counsel in this matter, the Attorney General is
not refusing to perform any legal duty but is instead exercising her
authority and discretion as provided by law. 1d.

Second, our office is neither dictating nor attempting to dictate the
terms ofyour engagement of outside counsel. My letter of March 15 to
Mr. Fenton authorized your office to join another entity's amicus brief
(at no cost to the taxpayers of Maine) or to retain private counsel to
file a separate amicus brief on your behalf in Hawaii v. Trump.
Consistent with the guidance provided by the Justices ofthe Maine
Supreme Judicial Court in 2015, we have not imposed any cap on the
hourly rate or total amount to be paid in fees to outside counsel, nor
have we suggested that our office review any invoices submitted for
payment. See Opinion ofthejustices, 2015 ME 27,136. Under the
circumstances, such tasks should properly be performed by licensed
attorneys in the Office of the Governor, not the Office of the Attorney
General. We have not imposed any constraints on your choice of
outside counsel; other than to state the obvious that the person or
firm should be properly licensed and insured, and admitted to
practice before the US. District Court in Hawaii.

Third, although this office is not currently participating as an amicus
in Hawaii Trump, the Attorney General retains authority to take a
position in that case that is contrary to the position you wish to take, if
she determines that to be in the best interest of the people of Maine.
See Opinion ofthejustices, 2015 ME 27, 1f 14; Superintendent oflns.,
558 A. 2d at 1204.

Finally, you suggest that there is ?historical precedent for the hiring of
outside counsel to be paid from the budget of the Office ofthe
Attorney General.? We are not aware ofany such precedent regarding
payment of fees for outside counsel to represent the Executive
Branch, nor are we aware ofany statutory basis for requiring
payment ofcounsel fees from this office's legislative appropriation.
Upon receipt ofyour letter on Friday afternoon, I asked Mr. Fenton if
he could please provide specifics underlying the reference to
?historical precedent.? He has yet to respond.

Once again, you have the Attorney General?s authorization to engage
outside counsel to represent you as an amicus in the matter of Hawaii
v. Trump, as indicated in my March 15 letter, consistent with 5 
191(3) and the Court's guidance cited above. lfyou have additional
questions or need further clarification, please let us know. Thank you.

21.

22.

23.

24.

25.

26.

The statute requiring that the Attorney General be the sole legal representative of State
officers is premised primarily on protecting the State from incurring legal costs for
outside attorneys. Therefore, the only legislative appropriation for State litigation is
that made to the office ofAttorney General. Because the Governor is entitled to legal
representation by the Attorney General, the Legislature makes no appropriation to the
Governor for litigation costs ofoutside attorneys.

The Attorney General has regularly requested funds to be appropriated by the
Legislature for a category known as, "Professional Services Not By State.? For fiscal
year 2017, the Attorney General requested and received an appropriation totaling
$192,657 for this purpose, excluding any such services for the State Medical Examiner
or the District Attorneys.

In the past, the Attorney General has used the appropriation for ?Professional Services
Not By State? to pay for legal services provided by private law firms.

The Governor does not receive an appropriation for such professional services.

lfthe Attorney General is permitted by statute to decline to represent the State without
making funds available for alternative representation, all state agencies and the
Executive branch are at risk of not being able to carry out their Constitutional and
statutorily-mandated functions if the Attorney General declines to represent them,
while at the same time remaining in control and possession of the entire appropriation
for state legal representation including ?Professional Services Not By State.?

Put another way, there must be a fiscal consequence to the Attorney General?s refusal to

provide legal representation to the State because the alternative would leave all State

agencies, the Governor and the Executive without legal representation at the discretion
of a sitting Attorney General.

27. On this state offacts, the Plaintiffis effectively obstructed by the Defendant in the
exercise of Plaintiff's duties and carrying out Plaintiff?s office as Governor because 
Defendant fails and refuses to advise and represent the Governor with respect to the
Order, as requested, Defendant fails and refuses to give approval for the Plaintiff to
obtain outside counsel without impermissible conditions and restrictions, and 
Defendant at the same time refuses to make funds available for Plaintiff?s outside
representation, although the Defendant would otherwise provide such representation
under the appropriation made for the Attorney General.

28. The attorney general statute, 5 M.R.S. 191, cannot grant to the Attorney General of
Maine the power to prevent the Governor of Maine from carrying out the executive
office ofthe Governor. Ifand insofar as the statute has that effect, then the statute
violates the proper separation ofpowers and is for that and other reasons
unconstitutional. Under the Constitution ofMaine there are only three branches of
government, not four. Therefore, the statute must be interpreted so to restrict the
authority and duties of the Attorney General of Maine as not to encroach upon, limit or
restrict the duties and authority of the Governor or any other branch of state

government under the Constitution ofMaine.
WHEREFORE, Plaintiff prays for judgment against the Defendant as follows:

1. Declaring that ifthe Attorney General refuses to represent the Governor ofthe State

when requested to do so in matters properly within the scope ofthe Governor?s

10

executive power under the Constitution of Maine, the Attorney General must authorize
the Governor to retain independent counsel without purporting to impose constraints
or limitations on the scope of the Governor?s representation by such counsel.

2. Declaring that when the Governor so retains outside counsel, because this relieves the
Attorney General of the performance of his or her duty to represent the Governor, the
costs of engaging the outside attorney must be paid out of the appropriation for the
Attorney General.

3. Making such further declaration or granting such further relief as the Court may

determine.

4. Ordering the Attorney General to conform to the Court?s declaration.

Respectfully submitted this 1st day ofMay 2017.

Edi $5?ch

M. Dench, Bar No 1005
Amy Dieterich, Bar No. 5413
Attorneys for Governor Paul R. LePage
SKELTON TAINTOR ABBOTT
95 Main Street
Auburn ME 04210
207-784-3200



11

SUMMARY SHEET

This sununaiy sheet and the information contained herein neither replace nor supplement the ?ling and service of pleadings or other
papers as required by the Maine Rules of Court or by law. This form is required for the use of the Clerk of Court for the purpose of
initiating or updating the civil docket sheet. (SEE INSTRUCTIONS ON REVERSE)

1. County of Filing District Court Jurisdiction: KENNEBEC COUNTY SUPERIOR COURT

 

II. CAUSE OF ACTION (Cite the primary civil statutes under which you are ?ling, if any.) Pro se plaintiffs: If unsure, leave blank.
14 MRS 5951, et seq; 5 M.R.S. 191

NATURE OF FILING

Initial Complaint

Third-Party Complaint

Cross-Claim or Counterclaim

If Reinstated or Reopened case, give original Docket Number
(If ?ling a second or subsequent Money Judgment Disclosure, give docket number of ?rst disclosure)



 

IV. TITLE TO REAL ESTATE IS INVOLVED

 

. MOST DEF IN ITIVE NATURE OF ACTION. (Place an in one box only) Pro se plaintiffs; If unsure, leave blank.
GENERAL CIVIL (CV)

<1

 

 

Personal Injury Tort Contract Other Forfeiture/Property Libels
CI Property Negligence CI Contract Land Use Enforcement (80K)
CI Auto Negligence Declaratory/Equitable Relief [3 Administrative Warrant
Medical Malpractice General Injunctive Relief Cl HIV Testing
CI Product Liability I Declaratory Cl Arbitration Awards
[3 Assault/Battery Cl Other Equitable Relief CI Appointment of Receiver
Cl Domestic Torts Constitutional/Civil Rights Cl Shareholders? Derivative Actions
Cl Other Negligence Constitutional/Civil Rights Cl Foreign Deposition
Other Personal Injury Tort Statutory Pre-action Discovery

Non-Personal Injury Tort Unfair Trade Practices Common Law Habeas Corpus
Libel/Defamation Cl Freedom of Access Prisoner Transfers
Cl Auto Negligence Other CI Foreign Judgments
Other Negligence CI Miscellaneous Civil Minor Settlements



Other Non-Personal Injury Tort

Drug Forfeitures

Other Civil

 

CHILD PROTECTIVE CUSTODY PC I

Protective Custody

Title Actions Foreclosure
El Quiet Title L-J Foreclosure exempt)
Cl Eminent Domain Foreclosure (Diversion eligible)
Cl Easements CI Foreclosure Other
Cl Boundaries

REAL ESTATE (RE)

UDCICI

SPECIAL ACTIONS (SA)

Money Judgment
Cl Money Judgment Request Disclosure

Misc. Real Estate
Equitable Remedies
Mechanics Lien
Partition
Adverse Possession

CI Nuisance

Cl Abandoned Roads
Trespass

Other Real Estate

 

 

APPEALS (To be ?led in Superior Court) (ADR exempt)

Cl Governmental Body (80B)

CI Administrative Agency (80C)

Cl Other Appeals

VI. 16B Alternative Dispute Resolution (ADR):

Cl I certify that pursuant to this case is exempt from a required ADR process because:

It falls within an exemption listed above an appeal or an action for non-payment of a note in a seemed transaction).
The plaintiff or defendant is incarcerated in a local, state or federal facility.
The parties have participated in a statutory prelitigation screening process with
The parties have participated in a formal ADR process with
(date).
This is a Personal Injuryr action in which the plaintiff?s likely damages 
exemption from ADR.

 

(name of neutral)



 



 

ill not exceed $30,000, and the plaintiff requests an

El

Rev. 08;?09

VII. (3) PLAINTIFFS (Name Address including county)
or Cl Third-Party, Cl Counterclaim or Cross-Claim Plaintiffs
The plaintiff is a prisoner in a local, state or federal facility.

Governor Paul R. LePage
1 State House Station
Augusta, ME 04333-0001
(Kennebec County)

phone Number) If all counsel listed do NOT represent all plaintiffs,

Attorneys (Name, Bar number, Firm name, Address, Tele
specify who the listed attorney(s) represent.

(If Pro se plaintiff, leave blank)

Bryan M. Dench, Esq. Bar No. 1005
Amy Dieterich, Esq. Bar No. 5413
Skelton, Taintor Abbott

95 Main Street

Auburn, ME 04210

(207) 784-3200

 

I (Name Address including county)
and/or Cl Third-Party, Cl Counterclaim or Cl Cross-Claim Defendant(s)
The defendant is a prisoner in a local, state or federal facility.

Attorney General Janet T. Mills
Of?ce of the Attorney General
Burton Cross Building, Sixth Floor
109 Sewall Street

Augusta, ME 04330

(Kennebec County)

phone Number) If all counsel listed do NOT represent all
defendants, specify who the listed attorney(s)

represent.

Attorneys (Name, Bar number, Firm name, Address, Tele
(If known)

 

1x. RELATED IF ANY

 

Docket Number

 

Assigned Judge/Justice

 

 

Date: May 1: 2017 Bryan M. Dench
Name ead rney of Record or Pro se Party
1 /24mr0icla2. c
Sigriblmomey or Pro se Party, 

SKELTON, TAINTOR ABBOTT
95 Main Street
Auburn, Maine 04210
Tel. (207) 784-3200
FAX (207) 784?3345

REQUEST FOR SERVICE

DATE: May 1, 2017

TO: Harry McKinney, Chief
Kennebec County Sheriff?s Of?ce
Civil Division
125 State Street
Augusta, ME 04330

CASE: Re: Governor Paul R. LePage
Vs: Attorney General Janet T. Mills
Kennebec Superior Court, Docket No. 17-

SERVE: Summons and Complaint

UPON: Defendant: Attorney General Janet T. Mills
Located at: Of?ce of the Attorney General
Burton Cross Building, 6th Floor
109 Sewall Street
Augusta, ME 04330

RETURN: Original Summons with executed oath

Should you have any questions, please contact me 784-3200, ext. 3026

SEND RETURN OF SERVICE TO: Midge Leblond, Legal Assistant
Skelton, Taintor Abbott

95 Main Street
Auburn, ME 04210

State ofMaine\Kennebec Sheriff Service AG Millsdocx

STATE OF MAINE

 

 

SUPERIOR COURT DISTRICT COURT
ss. Location
Docket No. Docket No.

Governor Paul R. LePage Plaintiff

SUMMONS

V.
M.R. Civ. P. 4(a)

Attorney General Janet MillDefendam
Uttice or the Attorney General

Burton Cross But%dings 5th 

 

Crux-:11 C+mnn


 

 

 

 

 

 

4?0?0 I I I 
Auguste, MF 04330

The Plaintiff has begun a lawsuit against you in the (Superior) Court, which
holds sessions at (street addressthe
Town/City of Augusta ,Countyof ,Maine.

If you wish to oppose this lawsuit, you or your attorney MUST PREPARE AND SERVE A
WRITTEN ANSWER to the attached Complaint WITHIN 20 DAYS from the day this
Summons was served upon you. You or your attorney must serve your Answer, by delivering a
copy of it in person or by mail to the Plaintiff attorney, or the Plaintiff, whose name and address
appear below. You or your attorney must also ?le the original of your Answer with the court by
mailing it to the following address: Clerk of KEEN) (Superior) Court, l. Li mb )9 

 

 

 

1 Court Street Augusta _,Maine 04330
(Mailing Address) (Town, City) (Zip)

before, or within a reasonable time after, it is served. Court rules governing the preparation and
service of Answer are found at 

IMPORTANT WARNING

NOTIFIES YOU TO DO SO, A JUDGMENT BY DEFAULT MAY BE ENTERED
AGAINST YOU IN YOUR ABSENCE FOR THE MONEY DAMAGES OR OTHER
RELIEF DEMANDED IN THE COMPLAINT. IF THIS OCCURS, YOUR EMPLOYER
MAY BE ORDERED TO PAY PART OF YOUR WAGES TO THE PLAINTIFF OR
YOUR PERSONAL PROPERTY, INCLUDING BANK ACCOUNTS AND YOUR REAL
ESTATE MAY BE TAKEN T0 SATISFY THE JUDGMENT. IF YOU INTEND TO
OPPOSE THIS LAWSUIT, DO NOT FAIL TO ANSWER WITHIN THE REQUIRED
TIME. 

If you believe the plaintiff is not entitled to all or part of the claim set forth in the
Complaint or if you believe you have a claim of your own against the Plaintiff, you should talk to
a lawyer. If you feel you cannot afford to pay a fee to a lawyer, you may ask the clerk of court
for information as to places where you may seek legal assistance.

(Seal of Court)

Date: May 1, 2017 Linda, 3 mm

Bryan M. Dench, Esq., Bar No. 1005 Clerk
Amy Dieterich, Esq., Bar No. 5413
(Attomeyfor) Plaintiff Skelton, Taintor Abbott

 

 

95 Main Street Address
Auburn, ME 04210
(207) 784-3200 Telephone

 

CV-030, Rev. 06/14

STATE OF MAINE

County of ,ss.

 

On (date), I served the Complaint (and Summons) upon Defendant
by delivering a copy of same at the following

 

address:

 

El to the above?named Defendant in hand.

El to (name), a person of suitable age and discretion who
was then residing at Defendant?s usual residence.

El

to (name), who is authorized to receive service for Defendant.



by (describe other manner of service):

 

 

Costs of Service:

 

 

Service: 3

Travel 5

Postage SS Signature
Other 

Total Agency

CV-OBO, Rev. 06/ 14