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).
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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 Plaintiffs 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.



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Dated this 8
th
day of August, 2014.


By: /s/ Scott K. Porsborg
Scott K. Porsborg
Cass County Special Assistant
States 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.
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CERTIFICATE OF SERVICE
Case No. 3-14-CV-57
I hereby certify that on August 8, 2014, the following document: JOINT
MEMORANDUM IN SUPPORT OF MOTION FOR EXTENSION OF TIME was filed
electronically with the Clerk of Court through ECF, and that ECF will send a Notice of
Electronic Filing (NEF) to Joshua Newville, Tom Fiebiger, and Scott Porsborg.

/s/ Douglas A. Bahr
Douglas A. Bahr
Solicitor General
State Bar ID No. 04940
Email dbahr@nd.gov

e:\dixie\cl\bahr\briefs\constitution.brf\jorgensen\pleadings\motion extension time memorandum.docx
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