Electronically Served
6/18/2018 3:02 PM
Dakota County, MN

19HA-CV-18-2643

STATE OF MINNESOTA
COUNTY OF DAKOTA

DISTRICT COURT
FIRST JUDICIAL DISTRICT
Case type: Civil
19HA-CV-18-2643
Court File No.

Michelle L. MacDonald, MacDonald
Law Firm, LLC,

)
)
)
)
)
Plaintiffs,
)
vs.
)
)
Michael Brodkorb, individually and
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doing business as
)
www.MissinginMinnesota.com,
Missing in Minnesota, LLC, and John )
)
and Mary Does,
)
Defendants. )

TO:

DEFENDANTS’ MOTION FOR RULE
11 SANCTIONS AGAINST
ATTORNEYS FOR PLAINTIFFS

PLAINTIFFS ABOVE-NAMED, and their attorneys, Michelle L.
MacDonald, 1069 South Robert Street, West St. Paul, Minnesota and Larry
A. Frost, 5123 W. 98th Street #111, Bloomington, Minnesota.
PLEASE TAKE NOTICE, that if the Summons and Complaint served and

filed in the above-captioned matter are not withdrawn with prejudice within
twenty-one (21) days of the date of this motion, the Defendants, by and through
their counsel, will present to the Court this motion seeking relief pursuant to Minn.
R. Civ. P. 11 as follows:
1)

An award of Attorneys’ fees and costs associated with the defense of
this matter;

2)

Dismissal of all pretended claims with prejudice;

 19HA-CV-18-2643

3)

Any such other relief of the Court deems appropriate, including but not
limited to directives of a non-monetary nature or a fine payable to the
Court, in addition to an award of attorneys’ fees to the Plaintiffs.

This motion is based upon all of the proceedings, the file, the accompanying
memorandum of law and affidavit of Nathan M. Hansen.
Dated: June 18, 2018

/e/ Nathan M. Hansen
Nathan M. Hansen
ATTORNEY FOR DEFENDANTS
Michael Brodkorb and
Missing in Minnesota, LLC
2440 North Charles Street, Ste 242
North St. Paul, MN 55109
651-704-9600
651-704-9604 (fax)
Attorney Reg. No. 0328017
nathan@hansenlawoffice.com
ACKNOWLEDGMENT

The undersigned hereby acknowledges that sanctions may be imposed
under the circumstances set forth in Minn. Stat. § 549.211.
Dated: June 18, 2018

/e/ Nathan M. Hansen
Nathan M. Hansen #0328017