Preview
73-CV-24-1303
Filed in District Court
State of Minnesota
2/21/2024 10:16 AM
STATE OF MINNESOTA DISTRICT COURT
COUNTY OF STEARNS SEVENTH JUDICIAL DISTRICT
Case Type: Employment
Deanna McDougle, Court File No.:
Plaintiff,
Vv. CIVIL COVER SHEET
(Non-Family Case Type)
First Class Hospitality Group, Inc., Minn. Gen. R. Prac. 104
Defendant.
Date Case Filed: February 26, 2024
This civil cover sheet must be filed by the initial filing lawyer or party, if unrepresented
by legal counsel, unless the court orders all parties or their legal counsel to complete this
form. Once the initial cover sheet is filed, opposing lawyers or unrepresented parties who
have not already been ordered to complete this form may submit their own cover sheet
within ten days after being served with the initial cover sheet. See Rule 104 of the
General Rules of Practice for the District Courts.
If information is not known to the filing party at the time of filing, it shall be
provided to the Court Administrator in writing by the filing party within seven (7)
days of learning the information. Any party impleading additional parties shall provide
the same information to the Court Administrator. The Court Administrator shall, upon
receipt of the completed certificate, notify all parties or their lawyers, if represented by
counsel, of the date of filing the action and the file number assigned.
ATTORNEY FOR PLAINTIFF ATTORNEY FOR DEFENDANT
Ryan H. Ahlberg (#0386520) Beth A. Jenson Prouty (#0389275)
AHLBERG LAW, PLLC ARTHUR, CHAPMAN, KETTERING,
Union Plaza Building, Suite 300 SMETAK & PIKALA, P.A.
Minneapolis, Minnesota 55401 500 Young Quinlan Building
(612) 900-2269 81 South Ninth Street
rahlberg@ahlberglaw.com Minneapolis, Minnesota 55402-3214
(612) 339-3500
baprouty@ArthurChapman.com
73-CV-24-1303
Filed in District Court
State of Minnesota
2/21/2024 10:16 AM
Note: If either Plaintiff or Defendant gets an attorney, the attorney’s name, address,
telephone number and attorney ID number must be given in writing to the Court
Administrator immediately.
1 Provide a concise statement of the case, including facts and legal basis:
Plaintiff brings employment claims under the Minnesota Human Rights Act. A
coworker of Plaintiff was violating Defendant’s employment policies but was not
disciplined because of his race, causing Plaintiff to quit, which was a constructive
discharge.
2 Date Complaint was served: January 11, 2024.
3. For Expedited Litigation Track (ELT) Pilot Courts only:
a. __ the parties jointly and voluntarily agree that this case shall be governed by
the Special Rules for the ELT Pilot. Date of Agreement:
b. __ the court is requested to consider excluding this case from ELT for the
following reasons:
Note: ELT is mandatory in certain cases, and where mandatory, exclusion may also be
sought under the Special Rules for ELT Pilot.
c. Anticipated number of trial witnesses:
d. Amount of medical expenses to date:
e. Amount of lost wages to date:
f. Identify any known subrogation interests:
4 Estimated discovery completion within 6 months from the date of this form.
5. Disclosure / discovery of electronically stored information discussed with other
party?
xX No Yes, date of discussion:
6. Proposed trial start date: February 1, 2024.
2
73-CV-24-1303
Filed in District Court
State of Minnesota
2/21/2024 10:16 AM
7 Estimated trial time: 2 days 0 hours (estimates less than a day must be stated in
hours).
8. Jury trial is:
__ Waived by consent of Plaintiff pursuant to Minn. R. Civ. P. 38.02.
X requested by Plaintiff (NOTE: Applicable fee must be enclosed).
Physical/mental/blood examination pursuant to Minn R. Civ. P. 35 is requested:
__ Yes X No
10. Identify any party or witness who will require interpreter services, and describe the
services needed (specifying language, and if known, particular dialect): None.
11. Issues in dispute: Factual averments, liability, damages.
12. Case Type / Category: Employment (NOTE: select case type from Form 22,
Subject Matter Index for Civil Cases, appended to the Minnesota Rules of Civil
Procedure).
13. Recommended Alternative Dispute Resolution (ADR) mechanism: Mediation.
Recommended ADR provider (known as a “neutral”): Sheila Englemeier, Mark
Bennett.
Recommended ADR completion date: August 1, 2024
If applicable, reasons why ADR not appropriate for this case: N/A.
73-CV-24-1303
Filed in District Court
State of Minnesota
2/21/2024 10:16 AM
By signing below, the attorney or party submitting this form certifies that the above
information is true and correct.
Dated: February 21, 2024 AHLBERG LAW, PLLC
/s/ Ryan H. Ahlberg
Ryan H. Ahlberg (#0386520)
Union Plaza Building, Suite 300
333 Washington Avenue North
Minneapolis, Minnesota 55401
(612) 900-2269
rahlberg@ahlberglaw.com
Attorney for Plaintiff
ACKNOWLEDGEMENT
The undersigned acknowledges that pursuant to Minn. Stat. § 549.211 sanctions
may be awarded by the Court for violation of said section.
Dated: February 21, 2024 /s/ Ryan H, Ahlberg
Ryan H. Ahlberg (#0386520)
Preview
73-CV-24-1303 Filed in District Court State of Minnesota 2/21/2024 10:16 AM STATE OF MINNESOTA DISTRICT COURT COUNTY OF STEARNS SEVENTH JUDICIAL DISTRICT Case Type: Employment Deanna McDougle, Court File No.: Plaintiff, Vv. CIVIL COVER SHEET (Non-Family Case Type) First Class Hospitality Group, Inc., Minn. Gen. R. Prac. 104 Defendant. Date Case Filed: February 26, 2024 This civil cover sheet must be filed by the initial filing lawyer or party, if unrepresented by legal counsel, unless the court orders all parties or their legal counsel to complete this form. Once the initial cover sheet is filed, opposing lawyers or unrepresented parties who have not already been ordered to complete this form may submit their own cover sheet within ten days after being served with the initial cover sheet. See Rule 104 of the General Rules of Practice for the District Courts. If information is not known to the filing party at the time of filing, it shall be provided to the Court Administrator in writing by the filing party within seven (7) days of learning the information. Any party impleading additional parties shall provide the same information to the Court Administrator. The Court Administrator shall, upon receipt of the completed certificate, notify all parties or their lawyers, if represented by counsel, of the date of filing the action and the file number assigned. ATTORNEY FOR PLAINTIFF ATTORNEY FOR DEFENDANT Ryan H. Ahlberg (#0386520) Beth A. Jenson Prouty (#0389275) AHLBERG LAW, PLLC ARTHUR, CHAPMAN, KETTERING, Union Plaza Building, Suite 300 SMETAK & PIKALA, P.A. Minneapolis, Minnesota 55401 500 Young Quinlan Building (612) 900-2269 81 South Ninth Street rahlberg@ahlberglaw.com Minneapolis, Minnesota 55402-3214 (612) 339-3500 baprouty@ArthurChapman.com 73-CV-24-1303 Filed in District Court State of Minnesota 2/21/2024 10:16 AM Note: If either Plaintiff or Defendant gets an attorney, the attorney’s name, address, telephone number and attorney ID number must be given in writing to the Court Administrator immediately. 1 Provide a concise statement of the case, including facts and legal basis: Plaintiff brings employment claims under the Minnesota Human Rights Act. A coworker of Plaintiff was violating Defendant’s employment policies but was not disciplined because of his race, causing Plaintiff to quit, which was a constructive discharge. 2 Date Complaint was served: January 11, 2024. 3. For Expedited Litigation Track (ELT) Pilot Courts only: a. __ the parties jointly and voluntarily agree that this case shall be governed by the Special Rules for the ELT Pilot. Date of Agreement: b. __ the court is requested to consider excluding this case from ELT for the following reasons: Note: ELT is mandatory in certain cases, and where mandatory, exclusion may also be sought under the Special Rules for ELT Pilot. c. Anticipated number of trial witnesses: d. Amount of medical expenses to date: e. Amount of lost wages to date: f. Identify any known subrogation interests: 4 Estimated discovery completion within 6 months from the date of this form. 5. Disclosure / discovery of electronically stored information discussed with other party? xX No Yes, date of discussion: 6. Proposed trial start date: February 1, 2024. 2 73-CV-24-1303 Filed in District Court State of Minnesota 2/21/2024 10:16 AM 7 Estimated trial time: 2 days 0 hours (estimates less than a day must be stated in hours). 8. Jury trial is: __ Waived by consent of Plaintiff pursuant to Minn. R. Civ. P. 38.02. X requested by Plaintiff (NOTE: Applicable fee must be enclosed). Physical/mental/blood examination pursuant to Minn R. Civ. P. 35 is requested: __ Yes X No 10. Identify any party or witness who will require interpreter services, and describe the services needed (specifying language, and if known, particular dialect): None. 11. Issues in dispute: Factual averments, liability, damages. 12. Case Type / Category: Employment (NOTE: select case type from Form 22, Subject Matter Index for Civil Cases, appended to the Minnesota Rules of Civil Procedure). 13. Recommended Alternative Dispute Resolution (ADR) mechanism: Mediation. Recommended ADR provider (known as a “neutral”): Sheila Englemeier, Mark Bennett. Recommended ADR completion date: August 1, 2024 If applicable, reasons why ADR not appropriate for this case: N/A. 73-CV-24-1303 Filed in District Court State of Minnesota 2/21/2024 10:16 AM By signing below, the attorney or party submitting this form certifies that the above information is true and correct. Dated: February 21, 2024 AHLBERG LAW, PLLC /s/ Ryan H. Ahlberg Ryan H. Ahlberg (#0386520) Union Plaza Building, Suite 300 333 Washington Avenue North Minneapolis, Minnesota 55401 (612) 900-2269 rahlberg@ahlberglaw.com Attorney for Plaintiff ACKNOWLEDGEMENT The undersigned acknowledges that pursuant to Minn. Stat. § 549.211 sanctions may be awarded by the Court for violation of said section. Dated: February 21, 2024 /s/ Ryan H, Ahlberg Ryan H. Ahlberg (#0386520)