62-CV-18-4145

STATE OF MINNESOTA
COUNTY OF RAMSEY

Filed in Second Judicial District Court
7/20/2018 11:21 AM
Ramsey County, MN

DISTRICT COURT
SECOND JUDICIAL DISTRICT
Case type: Civil
Court File No.
62-CV-18-4145

Michelle L. MacDonald, MacDonald
Law Firm, LLC,

)
)
)
)
)
Plaintiffs,
)
vs.
) DEFENDANTS’ MOTION FOR RULE
) 11 SANCTIONS AGAINST MICHELLE
Michael Brodkorb, individually and
L. MACDONALD
)
doing business as
)
www.MissinginMinnesota.com,
Missing in Minnesota, LLC, and John )
)
and Mary Does,
)
Defendants. )

TO:

PLAINTIFFS ABOVE-NAMED, and Michelle L. MacDonald, 1069 South
Robert Street, West St. Paul, Minnesota
The Plaintiffs have filed the same lawsuit in two counties in Minnesota.

Prior to filing the instant case, the Plaintiffs filed this lawsuit in Dakota County on
June 15, 2018 and case number 19HA-CV-18-2643 was assigned. As of the date
of this memorandum, that case is pending and the Dakota County Court has issued
a scheduling order. The undersigned has spoken on the telephone with Michelle
MacDonald about dismissing this Ramsey County Case and she declined to do so.
MINNESOTA RULE OF CIVIL PROCEDURE 11
Minn. R. Civ. P. 11.02 states in relevant part as follows:
“11.02 Representations to Court

 62-CV-18-4145

Filed in Second Judicial District Court
7/20/2018 11:21 AM
Ramsey County, MN

By presenting to the court (whether by signing, filing, submitting, or later
advocating) a pleading, written motion, or other document, an attorney or selfrepresented litigant is certifying that to the best of the person's knowledge,
information, and belief, formed after an inquiry reasonable under the
circumstances:
(a) it is not being presented for any improper purpose, such as to harass or to
cause unnecessary delay or needless increase in the cost of litigation;
The Defendants contend that the Complaint in this case violates the above
provision of Minn. R. Civ. P. 11.02. Specifically, the filing of the same lawsuit in
two counties is harassing and creates needless increase in the cost of litigation.
CONCLUSION
Based upon the foregoing, the Defendants respectfully request that the
relief sought in the instant motion be granted by the Court. The undersigned states
under penalty of perjury that the factual assertions in this memorandum are true
and correct.
Respectfully submitted,
Dated: July 19, 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

 62-CV-18-4145

Filed in Second Judicial District Court
7/20/2018 11:21 AM
Ramsey County, MN

ACKNOWLEDGMENT
The undersigned hereby acknowledges that sanctions may be imposed
under the circumstances set forth in Minn. Stat. § 549.211.
Dated: June 25, 2018

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