Letter,Correspondence: Erik A. Ahlgren, as assignee for creditors of Ashby Farmers Co-Op Elevator Co vs Plumbers, Inc.

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                                26-CV-20-175
                                                                                                           Filed in District Court
                                                                                                             State of Minnesota
                                                                                                           9/21/2023 10:41 AM


                                                                         2200 IDS Center, 80 South 8th Street
                                                                         Minneapolis, MN 55402-2210
                                                                         Tel: 612.977.8400 | Fax: 612.977.8650
                                                                         taftlaw.com
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Mark G. Schroeder
612.977.8450
MSchroeder@taftlaw.com




                                                 September 21, 2023



VIA E-FILING

The Honorable Amy J. Doll
Judge of the District Court
Grant County Courthouse
10 2nd St. NE
Elbow Lake, MN 56531

         Re:       Erik A. Ahlgren, in his capacity as assignee in the assignment for the benefit
                   of creditors of Ashby Farmers Co-Operative Elevator Company v. Marvin
                   Gaston, Betty Gaston, and Taxidermy Unlimited, Inc.; Plumbers, Inc.; and
                   Matt Skjeret and Skjeret Concrete

                   Court File Nos.: 26-CV-19-201; 26-CV-20-174; 26-CV-20-175

Dear Judge Doll:

        This letter, which has been reviewed and approved by Plaintiff's counsel, is submitted
jointly on behalf of Plaintiff and Defendants in the three above-referenced actions.

        Following up on our informal hearing of last week, my firm has consulted with Defendants
and they hereby waive their jury demands. As such, the parties are prepared to try these cases
before the Court during the week of November 27, 2023 (which is the backup date set aside by the
Court in its recent notice of hearing).

        In light of the new trial date, and due to schedules and deadlines in unrelated litigation,
Defendants request a short extension of the deadline to file pretrial submissions in these actions
(now set for Monday, September 25) until Wednesday, September 27. Plaintiff does not oppose
this extension.

       The parties remain ready to proceed with a pretrial conference on October 2 (as previously
scheduled).

         Thank you for your time and consideration.



Taft Stettinius & Hollister LLP / Taftlaw.com / The Modern Law Firm
129072445v1
                                        26-CV-20-175
                                                                                Filed in District Court
                                                                                  State of Minnesota
                                                                                9/21/2023 10:41 AM




September 21, 2023
Page 2



                                              Respectfully,

                                              Taft Stettinius & Hollister LLP

                                              /s/ Mark G. Schroeder

                                              Mark G. Schroeder

MGS:amw
cc:  Counsel of Record (via E-Filing)
     Erik Ahlgren (via email)
     Adam Chandler (via email)




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