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27-CV-25-2808 <br />Filed in District Court <br />State of Minnesota <br />2/15/2025 12:08 PM <br />CLAIM FOR RELIEF <br />WHEREFORE, Petitioner respectfully prays for an Order of the Court as <br />follows: <br />A. Immediately setting a briefing schedule and time for hearing, pursuant to <br />Minn. Stat. § 204B.44(b), such that: <br />1. Respondents' brief is due Friday, February 21, 2025 at 4:30 PM, <br />2. Any reply brief of Petitioner is due by Tuesday, February 25, 2025 at <br />4:30 PM, and <br />3. A hearing takes place no later than February 28, 2025, or at such <br />sooner or other times as the Court may direct; <br />B. Ordering Respondents to correct the wrongful acts and errors described herein <br />or show cause for not doing so at the aforementioned hearing; <br />C. Quashing City of Orono Resolution No. 7554, or ordering its recall; ordering <br />Respondents to take all steps necessary to cancel the special election they <br />scheduled for May 13, 2025; and enjoining all Respondents from taking any <br />action to hold a special election for Orono City Council Member Berrett's seat <br />on May 13, 2025; <br />D. Granting Petitioner such other and further relief as the Court deems just and <br />appropriate. <br />Dated: February 15, 2025 UPPER MIDWEST LAW CENTER <br />/s/ James V. F. Dickey <br />Douglas P. Seaton (#127759) <br />James V. F. Dickey (#393613) <br />Austin M. Lysy (#505052) <br />12600 Whitewater Dr., Suite 140 <br />Minnetonka, Minnesota 55343 <br />doug.seaton@umlc.org <br />james.dickey@umlc.org <br />austin.lysy@umlc.org <br />(612) 428-7000 <br />Attorneys for Petitioner <br />27 <br />82 <br />