Scribd Logo
Upload

Welcome to Scribd!

  • 1K views

    Amended Notice of Motion and Motion To Compel Mrs. Evavold's Deposition, Etc.

    Uploaded by

    mikekvolpe
    State Farm Fire & Casualty Company filed a motion in Dakota County District Court against multiple defendants including Deirdre Elise Evavold. State Farm seeks an order from the court compelling Ms. Evavold to appear for a deposition before October 1, 2019. State Farm also seeks an order directing Darin Evavold to comply with a subpoena and appear for his deposition, with the threat of contempt of court if he fails to appear. Finally, State Farm requests modification of the current scheduling order and reimbursement of expenses and attorney's fees related to bringing this motion.

    Copyright:

    © All Rights Reserved
    Download as PDF, TXT or read online from Scribd

    Amended Notice of Motion and Motion To Compel Mrs. Evavold's Deposition, Etc.

    Uploaded by

    mikekvolpe
    1K views3 pages
    State Farm Fire & Casualty Company filed a motion in Dakota County District Court against multiple defendants including Deirdre Elise Evavold. State Farm seeks an order from the court compelling Ms. Evavold to appear for a deposition before October 1, 2019. State Farm also seeks an order directing Darin Evavold to comply with a subpoena and appear for his deposition, with the threat of contempt of court if he fails to appear. Finally, State Farm requests modification of the current scheduling order and reimbursement of expenses and attorney's fees related to bringing this motion.

    Original Description:

    State Farm demands its own clients be deposed.

    Original Title

    Amended Notice of Motion and Motion to Compel Mrs. Evavold's Deposition, Etc.

    Copyright

    © © All Rights Reserved

    Available Formats

    PDF, TXT or read online from Scribd

    Did you find this document useful?

    Is this content inappropriate?

    State Farm Fire & Casualty Company filed a motion in Dakota County District Court against multiple defendants including Deirdre Elise Evavold. State Farm seeks an order from the court compelling Ms. Evavold to appear for a deposition before October 1, 2019. State Farm also seeks an order directing Darin Evavold to comply with a subpoena and appear for his deposition, with the threat of contempt of court if he fails to appear. Finally, State Farm requests modification of the current scheduling order and reimbursement of expenses and attorney's fees related to bringing this motion.

    Copyright:

    © All Rights Reserved
    Download as PDF, TXT or read online from Scribd
    Download as pdf or txt
    1K views3 pages

    Amended Notice of Motion and Motion To Compel Mrs. Evavold's Deposition, Etc.

    Uploaded by

    mikekvolpe
    State Farm Fire & Casualty Company filed a motion in Dakota County District Court against multiple defendants including Deirdre Elise Evavold. State Farm seeks an order from the court compelling Ms. Evavold to appear for a deposition before October 1, 2019. State Farm also seeks an order directing Darin Evavold to comply with a subpoena and appear for his deposition, with the threat of contempt of court if he fails to appear. Finally, State Farm requests modification of the current scheduling order and reimbursement of expenses and attorney's fees related to bringing this motion.

    Copyright:

    © All Rights Reserved
    Download as PDF, TXT or read online from Scribd
    Download as pdf or txt
    of 3

    STATE OF MINNESOTA DISTRICT COURT

    COUNTY OF DAKOTA FIRST JUDICIAL DISTRICT

    Type of Case: Civil Other/Misc.

    State Farm Fire & Casualty Company, Court File No. 19-HA-CV-18-905
    The Honorable Jerome B. Abrams
    Plaintiff,
    v.
    STATE FARM FIRE AND
    David V. Rucki; Samantha Rucki; CASUALTY COMPANY’S
    Gianna Rucki; Sandra Sue Grazzini- AMENDED NOTICE OF MOTION
    Rucki; Deirdre Elise Evavold; Destiny AND AMENDED MOTION TO
    Equine Intervention d/b/a White Horse COMPEL THE DEPOSITION OF
    Ranch, a Minnesota Nonprofit DEFENDANT DEIRDRE ELISE
    Corporation; Gina Schmit Dahlen; EVAVOLD, ISSUANCE OF A
    Douglas Dahlen; Destiny Church; DIRECTIVE TO DARIN
    Steve Quernemoen and Trish EVAVOLD, AND MOTION TO
    Quernemoen, MODIFY THE SCHEDULING
    ORDER
    Defendants.

    TO: All Defendants, above-named.

    NOTICE OF MOTION

    PLEASE TAKE NOTICE that State Farm Fire and Casualty

    Company (“State Farm”) will bring a motion for hearing before the

    Honorable Jerome B. Abrams at the Dakota County District Court, 14955

    Galaxie Ave. West, Apple Valley, MN 55124, on the 18th day of

    September, 2019, at 9:00 a.m., or as soon thereafter as counsel may be

    heard.
    MOTION

    Pursuant to Rules 26, 30 and 37 of the Minnesota Rules of Civil

    Procedure, State Farm moves this Court for an order as follows:

    1. Compelling Deirdre Elise Evavold to appear for the duly

    noticed deposition at a date and time certain, to be set by State Farm,

    before October 1, 2019.

    Pursuant to the Court’s inherent power and discretion to fashion

    discovery orders, State Farm moves this Court for an order as follows:

    1. Issuing a directive to Darin Evavold to comply with the issued

    subpoena and appear for his deposition. And that should he fail to appear

    for his deposition, the Court will hold him in contempt of court.

    Pursuant to the Rule 37.04, State Farm moves this Court as follows:

    1. Ordering that Mrs. Evavold pay State Farm’s incurred

    reasonable expenses and attorney’s fees in bringing this pending motion.

    Pursuant to Rule 16.02 of the Minnesota Rules of Civil Procedure,

    the State Farm moves this Court for an order as follows:

    1. Modifying the current Scheduling Order.

    This motion is based upon the supporting memorandum of law,

    arguments of counsel, the affidavits and exhibits submitted therewith, and

    submissions already on file with the Court.

    2
    Dated: September 4, 2019 HKM, P.A.

    s/ Lehoan T. Pham
    C. Todd Koebele, #1728X
    Lehoan T. Pham, #0397635
    30 East Seventh Street, Suite 3200
    St. Paul, MN 55101-4919
    Telephone: (651) 227-9411
    Fax: (651) 223-5199
    [email protected]
    [email protected]

    Attorneys for Plaintiff State Farm Fire


    and Casualty Company

    4824-3325-5328, v. 1

    You might also like