As promised, the Roe/Doe Attorneys, Jorgensen, Hatch, Bronster and Woodruff have filed motions with the Federal District Court for injunctive relief from the Emergency Order issued by Fitial.
Here are the three groups of documents that were filed:
Below are additional motions filed yesterday in U.S. District Court Civil Action No. 09-00023, seeking an emergency hearing for injunctive/related relief, and seeking to file a second amended complaint on plaintiffs’ behalf.
1 – EMERGENCY MOTION – leave file SAC
2 – AFFIDAVIT OF RMH re Mt Leave file SAC
3 – Exh A – Second Amended Complaint
Below is a motion and Exhibits A-H, filed yesterday in U.S. District Court Civil Action No. 09-00023, seeking a temporary restraining order and injunctive relief precluding implementation/perpetuation of CNMI Governor Benigno R. Fitial’s recently issued ‘emergency order’, which ‘emergency order’ purports to dissolve the Northern Mariana Islands Retirement Fund and to place the Fund’s assets under control of Fitial’s administration via the CNMI Departjment of Finance.
1 -EMERGENCY MOTION – TRO to prevent distribution
3 -Exh A – (008) Decl of Villagomez
4 – Exh B – CNMI Executive Order No. 2012-06
5 -Exh C – 09-06-29 Fund.Judgment.06.0367.Damages
6 -Exh D – 12-04-17 (001) Chapter 11 Voluntary Petition (NMI Retirement Fund)
7 -Exh E – 12-04-20 (024) Mtn to Dismiss Petition for BK
8 -Exh F- 12-06-13 (153) MEMO OF DECISION ON MOTIONS TO DISMISS
9 -Exh G- Certification of Board Vote re Villagomez
10 – Exh H – Alepuyo Appointment
11 – Exh I -buckingham-resigns-again-alepuyo-named-acting-ag.php
Below is a motion, declaration, and Exhibits A-M, filed yesterday in U.S. District Court Civil Action No. 09-00023, seeking to lift the stay originally issued January 25, 2010, which stay preceded the 9th Circuit Court’s October 17, 2011 dismissal of the Fund’s appeal, and the U.S. Bankruptcy Court’s subsequent August 15, 2012 dismissal of the Fund’s Chapter 11 bankruptcy petition.
1 -EMERGENCY MOTION – TO LIFT STAY
2 – Declaration RMH re Mt Lift Stay
Exh A – (008) Decl of Villagomez
Exh B – CNMI Executive Order No. 2012-06
Exh C – (217) Omnibus Reply to Obj & Responses re compensation
Exh D – 10-01-25 (072) Order Staying Proceedings 60 days
Exh E – 10-04-09 (078) Order to submit status rpts & continuing stay
Exh F – 11-09-08 (123) Order Denying (105) Rqst status conf & Mtn to Lift Stay
Exh G – 12-04-05 (157) CNMI’s Non-Consent to Mediation
Exh H – 12-04-06 (159) Trustees Notice re Mediation Statement
Exh I – 12-04-17 (001) Chapter 11 Voluntary Petition (NMI Retirement Fund)
Exh J – 12-04-20 (024) Mtn to Dismiss Petition for BK
Exh K – 12-06-13 (153) MEMO OF DECISION ON MOTIONS TO DISMISS
Exh L – SECOND AMENDED COMPLAINT (final)
Exh M – Certification of Board Vote re Villagomez
