AEM vs North Dakota – Reply In Support Of AEM Motion To Compel
Case 1:17-cv-00151-DLH-CSM
UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF NORTH DAKOTA
AEM vs North Dakota
Link to Document 88 Filed 05/18/18 Page 1 of 10
Reply In Support Of The Manufacturers’ Motion To Compel
NDIDA’s Response To Document Request No. 4
And To Make Matthew Larsgaard Available For Supplemental Deposition
I. ARGUMENT
A. NDIDA’s Interpretation of Request No. 4 Is Untenable.
B. The Stipulated Protective Order Addresses the First Amendment Concerns of NDIDA Members Claiming to Fear Reprisal for Their Lobbying Efforts.
C. NDIDA’s Internal Documents Are Likely to Be Highly Relevant.
II. CONCLUSION