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Agenda - Council - 04/08/2008
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Agenda - Council - 04/08/2008
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Meetings
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Agenda
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Council
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04/08/2008
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<br />u.s. 240 (1975)); Kallak v. Medtronic, Inc., 573 N.W.2d 356, 363 (Minn. 1998)). Because Look <br /> <br />has no contractual, statutory, or rule-based support for his fee demand, it must be denied. <br /> <br />CONCLUSION <br /> <br />This Court should reject Look's attempt to prevent PACT from moving forward with its <br /> <br />enrollment process which has not yet and may never harm Look's son. The illusory and <br /> <br />speculative harm Look asserts is not the irreparable harm upon which temporary injunctions are <br /> <br />granted. More importantly, Look has not properly asserted the prerequisites for a class action, he <br /> <br />identifies no right that entitles his son to the remedy he seeks, and any threatened harm to Look's <br /> <br />son is speculative at best. His claims do not merit an order to enjoin PACT from continuing the <br /> <br />status quo and administering its lottery. Indeed, Look's ultimate request to rework PACT's <br /> <br />preference.system would violate Minnesota law, and shift the supposed harm from. Look's child <br /> <br />to another student wishing to attend PACT rather than another available public school. Because <br /> <br />each of the Dahlberg factors weighs against injunctive relief, and Look has not met Rule 65's <br /> <br />requirements for injunctive relief, the motion for the extraordinary remedy of a temporary <br /> <br />injunction must be denied. Moreover, because plaintiff cannot establish that PACT's <br /> <br />admission's process violates Minnesota law, he fails to state a claim upon which relief may be <br /> <br />granted and his Complaint must thus be dismissed. <br /> <br />Dated: March 17, 2008 <br /> <br />BRIGGS AND MORGAN, P.A. <br /> <br />By <br />Samuel Hanson (#41051) <br />Diane Bratvold (#1 8696X) <br />2200 IDS Center <br />80 South Eighth Street <br />Minneapolis, MN 55402 <br />Phone: 612-977-8400 <br /> <br />22 <br /> <br />-149- <br />
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