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CASE 0:12-cv-01958-SRN-AJB Document 64 Filed 06/27/13 Page 1 of 4

UNITED STATES DISTRICT COURT DISTRICT OF MINNESOTA Michael Brodkorb, Plaintiff, v. Minnesota Senate, Defendant. AFFIDAVIT OF CHRISTOPHER J. HARRISTHAL IN SUPPORT OF DEFENDANTS MOTION TO COMPEL DISCOVERY RESPONSES (Exhibits C D and F - K Filed Under Seal)

File No. 12-CV-01958 (SRN/AJB)

STATE OF MINNESOTA COUNTY OF HENNEPIN

) ) ss. )

Christopher J. Harristhal, being first duly sworn, upon oath, deposes and states: 1. I am an attorney with Larkin Hoffman Daly & Lindgren, Ltd., counsel for

Defendant Minnesota Senate in the above-captioned action. 2. Attached hereto as Exhibit A is a true and correct copy of the Affidavit of Service,

dated April 8, 2013, serving Defendants Interrogatories to Plaintiff (Set I), Defendants Request for Production of Documents to Plaintiff (Set I) and blank medical and employment authorizations. 3. Attached hereto as Exhibit B is a true and correct copy of Plaintiffs Answers to

Defendants First Set of Interrogatories, dated May 24, 2013 4. Attached hereto as Exhibit C is a true and correct copy of Plaintiffs Answers to

Defendants First Set of Interrogatories Attorneys Eyes Only, dated May 24, 2013. (Filed under

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seal pursuant to the Confidential designations by Plaintiff Michael Brodkorb under the Protective Order issued by the Court.) 5. Attached hereto as Exhibit D is a true and correct copy of Plaintiffs Initial

Disclosures, dated April 25, 2013. (Filed under seal pursuant to the Confidential designations by Plaintiff Michael Brodkorb under the Protective Order issued by the Court.) 6. Attached hereto as Exhibit E is a true and correct copy of Plaintiffs Answers to

Defendants First Set of Requests for Production of Documents, dated May 24, 2013, served May 28, 2013. 7. Attached hereto as Exhibit F is a true and correct copy of correspondence from

Attorney Harristhal to Attorney Walsh, dated May 28, 2013. Plaintiff did not accept my invitation to meet and confer on any of the dates I proposed in that letter. (Filed under seal pursuant to the Confidential designations by Plaintiff Michael Brodkorb under the Protective Order issued by the Court.) 8. Attached hereto as Exhibit G is a true and correct copy of correspondence from

Attorney Walsh to Attorney Harristhal, dated May 31, 2013. Plaintiffs counsel never responded to my letter of May 31, 2013 before we prepared our motion papers and no explanation have been provided for the refusals to produce documents and information addressed in my letter. My offer to meet and confer on June 3, 4 or 5 was not accepted. (Filed under seal pursuant to the Confidential designations by Plaintiff Michael Brodkorb under the Protective Order issued by the Court.) 9. Attached hereto as Exhibit H is a true and correct copy of correspondence from

Attorney Harristhal to Attorney Walsh, dated May 31, 2013. (Filed under seal pursuant to the

2.

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Confidential designations by Plaintiff Michael Brodkorb under the Protective Order issued by the Court.) 10. Attached hereto as Exhibit I is a true and correct copy of correspondence from

Attorney Harristhal to Attorney Walsh, dated June 6, 2013. Plaintiffs counsel never responded to my letter of June 6, 2013 and no explanations have been provided for the refusals to produce information addressed in my letter. (Filed under seal pursuant to the Confidential designations by Plaintiff Michael Brodkorb under the Protective Order issued by the Court.) 11. Although I do not regard it as a response to my letters of June 6 or May 31,

because of the time lapse and failure to address most of the topics I raised, we did receive a letter in the afternoon of June 26, 2013 from Greg Walsh, after our memorandum of law was drafted, which enclosed employment authorizations and indicated that Plaintiff will be requesting his medical records from the one physician identified in the answer to Interrogatory No. 4, and that copies would be provided to us. A copy of that correspondence is attached as Exhibit J. (Filed under seal pursuant to the Confidential designations by Plaintiff Michael Brodkorb under the Protective Order issued by the Court.) 12. Attached hereto as Exhibit K is a true and correct copy of an email string between

Attorney Harristhal and Attorney Walsh, spanning June 13, 2013 through June 24, 2013. (Filed under seal pursuant to the Confidential designations by Plaintiff Michael Brodkorb under the Protective Order issued by the Court.) 13. Attached hereto as Exhibit L is a true and correct copy of the article Michael

Brodkorb pleads guilty to DWI in January crash, by Marino Eccher of the Pioneer Press, accessed March 13, 2013.

3.

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14.

Attached hereto as Exhibit M is a true and correct copy of the article Michael

Brodkorb pleads guilty to DWI in January crash, by Marino Eccher of Pioneer Press, accessed April 17, 2013. 15. Attached hereto as Exhibit N is a true and correct copy of the article Michael

Brodkorb crash: Former Senate staffer critically injured KMSP-TV, dated January 25, 2013. FURTHER YOUR AFFIANT SAYETH NOT. s/ Christopher J. Harristhal Christopher J. Harristhal (175754) Subscribed and sworn to before me this 27th day of June, 2013. s/ Tammy Jo Estrem________________ Notary

1462954.1

4.

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CASE 0:12-cv-01958-SRN-AJB Document 64-4 Filed 06/27/13 Page 1 of 1 UNITED STATES DISTRICT COURT DISTRICT OF MINNESOTA Michael Brodkorb, Plaintiff, v. Minnesota Senate, Defendant. PLACE HOLDER FOR CONFIDENTIAL EXHIBITS C D AND F - K TO CHRISTOPHER J. HARRISTHALS AFFIDAVIT IN SUPPORT OF DEFENDANTS MOTION TO COMPEL DISCOVERY RESPONSES File No. 12-CV-01958 (SRN/AJB)

This document is a place holder for the following item(s) which are filed in conventional or physical form with the Clerk's Office: Exhibits C D and F - K to Christopher J. Harristhals Affidavit in Support of Defendants Motion to Compel Discovery Responses which have been designated as Confidential by Plaintiff Michael Brodkorb If you are a participant in this case, this filing will be served upon you in conventional format. This filing was not e-filed for the following reason(s): ___ Voluminous Document* (Document number of order granting leave to file conventionally: ___ ) ___ Unable to Scan Documents (e.g., PDF file size of one page larger than 15MB, illegible when scanned) ___ Physical Object (description): ___ Non Graphical/Textual Computer File (audio, video, etc.) on CD or other media _X_ Item Under Seal pursuant to a court order (Document number of protective order: 58 ) ___ Item Under Seal pursuant to the Fed. R. Civ. P. 5.2 and Fed. R. Crim. P. 49.1
(Document number of redacted version: ___ )

___ Other (description):

forms\cmecf\convfilingplchldr.doc

Form Updated 07/29/05

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