CASE 0:12-cv-01958-SRN-AJB Document 60 Filed 06/27/13 Page 1 of 2

UNITED STATES DISTRICT COURT DISTRICT OF MINNESOTA Michael Brodkorb, Plaintiff, v. Minnesota Senate, Defendant. DEFENDANTS MOTION TO COMPEL DISCOVERY RESPONSES

File No. 12-CV-01958 (SRN/AJB)

Pursuant to Rules 37 and 16 of the Federal Rules of Civil Procedure, Plaintiff Minnesota Senate hereby moves this Court for an Order: 1. Ordering Plaintiff to provide complete answers and documents responsive to Defendants Interrogatories (Set I) Nos. 4, 6, and 13 and Requests for Production of Documents (Set I) Nos. 1, 4, 9, and 13, within five (5) business days after the date of the order. 2. Ordering that said documents, papers, letters, objects and tangible things responsive to Defendants Requests for Production of Documents (Set I) and identified in his Initial Disclosures be produced at the law offices of Larkin Hoffman Daly & Lindgren Ltd., 1500 Wells Fargo Plaza, 7900 Xerxes Avenue South, Minneapolis, Minnesota 55431, within five (5) business days after the date of the order. 3. Ordering that Plaintiff execute authorizations for the release of medical information. 4. Ordering Plaintiff to provide a full and complete disclosure with respect to alleged damages, including all computations and categories.

CASE 0:12-cv-01958-SRN-AJB Document 60 Filed 06/27/13 Page 2 of 2

5. Ordering Plaintiff to pay Defendants reasonable and necessary attorneys fees and costs incurred in conjunction with bringing this motion. This Motion is based on all files, records, oral argument, and other proceedings in this matter, including Plaintiffs Memorandum of Law and the Affidavit of Christopher J. Harristhal filed in support of this motion.

Dated: June 27, 2013

s/ Christopher J. Harristhal Dayle Nolan (121290) Christopher J. Harristhal (175754) Larkin Hoffman Daly & Lindgren Ltd. 7900 Xerxes Avenue South, Ste. 1500 Minneapolis, Minnesota 55431-1194 Phone: (952) 896-3275 Fax: (952) 842-1725 dnolan@larkinhoffman.com charristhal@larkinhoffman.com Attorneys for Defendant Minnesota Senate

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