Post on 02-Jun-2018
transcript
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Peter K. Michael, (Wyo. Bar. No. 5-2309)
Attorney General of WyomingMartin L. Hardsocg (Wyo. Bar No. 6-2919)
Deputy Attorney General
James C. Kaste, (Wyo. Bar No. 6-3244)
Deputy Attorney General
Jared S. Crecelius (Wyo. Bar No. 6-4118)
Senior Assistant Attorney General
Ryan T. Schelhaas (Wyo. Bar No. 6-3321)Senior Assistant Attorney General
Michael M. Robinson (Wyo. Bar. No. 6-2658)Senior Assistant Attorney General
Wyoming Attorney Generals Office
123 State Capitol Building
Cheyenne, WY 82002
(307) 777-7876
(307) 777-3687 fax
UNITED STATES DISTRICT COURT
DISTRICT OF WYOMING
Anne Marie Guzzo and Bonnie Robinson; )Ivan Williams and Charles Killion; )
Brie Barth and Shelly Montgomery; )
Carl Oleson and Rob Johnston; and )
Wyoming Equality, )
)
Plaintiffs, )
)
v. ) Civil No. 14-CV-200-SWS
)
Matthew H. Mead, in his official capacity as )the Governor of Wyoming; Dean Fausset, in )
his official capacity as Director of the )
Wyoming Department of Administration and )
Information; Dave Urquidez, in his official )
Capacity as Administrator of the State of )
Wyoming Human Resources Division; and )
Debra K. Lathrop, in her official capacity )
as Laramie County Clerk, )
)
Defendants. )
GOVERNOR MEADS MOTION TO QUASH SUBPOENA
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Defendant, Governor Matthew H. Mead, through the Office of the Attorney
General, hereby moves to quash the Subpoena to Appear and Testify at a Hearing or Trial
in a Civil Action, served on Governor Meads Deputy Chief of Staff by Plaintiffs on
October 9, 2014. In support of this motion, Governor Mead states as follows:
1. On October 7, 2014, Plaintiffs initiated this case by filing their Complaint
for Declaratory and Injunctive Relief, alleging that the State of Wyoming unlawfully
denies same sex couples the right to marry. Compl. at 1. The following day, Plaintiffs
filed a motion for a preliminary injunction and temporary restraining order barring the
Defendants from enforcing Wyo. Stat. Ann. 20-1-101 and requiring them to issue or
permit the issuance of marriage licenses to same sex couples. Mot. for Prelim. Inj. at
9-10. On October 9, 2014, the Court set Plaintiffs motion for preliminary injunction for
hearing on October 16, 2014, at 10:00 a.m., in Casper, Wyoming. Despite regular
communications between the parties both before and after the filing of this suit, counsel
for Governor Mead was not advised that Plaintiffs would seek to compel the Governor to
testify at the hearing.
2. On the evening of October 9, 2014, five minutes before the scheduled start
of a debate between gubernatorial candidates, two unidentified individuals approached
Governor Meads staff and security detail on the campus of Casper College. Mead Aff.
at 2. These individuals attempted to serve Governor Mead with a Subpoena to Appear
and Testify at a Hearing or Trial in a Civil Action commanding Governor Mead to appear
at the hearing of Plaintiffs motion for preliminary injunction. Id. Governor Meads
Deputy Chief of Staff received the subpoena on his behalf, and a copy of the subpoena is
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attached hereto as Exhibit A.1 Id. At no time prior to service of the subpoena did
Plaintiffs approach counsel for Governor Mead to inquire whether they would accept
service of the subpoena on his behalf.2
3. Under Federal Rule of Civil Procedure 45, on timely motion a court must
quash or modify a subpoena that either fails to allow a reasonable time to comply or
subjects a person to an undue burden. Fed. R. Civ. P. 45(d)(3)(A)(i) and (iii). This
subpoena should be quashed for both reasons.
4. First, the subpoena fails to give Governor Mead a reasonable time to
comply. Although Rule 45 does not define reasonable time, many courts have found
that anything less than fourteen days from the date of service is not reasonable. SEC v.
Art Intellect, Inc., 2012 WL 776244, at *3 fn.43 (D. Utah March 7, 2012) (listing cases);
Tri Investments, Inc. v. Aiken Cost Consultants, 2011 WL 5330295, at *2 (W.D.N.C.
November 7, 2011) (citing cases).
5. This subpoena only gives Governor Mead seven total and five working
days notice of the hearing. Ex. A. For most witnesses five working days notice does not
provide enough time to rearrange their professional and personal schedules without
1Governor Mead does not assert that service of the subpoena was defective because it
was accepted by the Deputy Chief of Staff rather than served on the Governor personally.
See Fed. R. Civ. P. 45 (b)(1). However, the subpoena was not accompanied by therequired witness fee and mileage allowance. Id.
2 Concerned that service upon the Deputy Chief of Staff was defective, upon the
suggestion of counsel for Governor Mead, Plaintiffs eventually requested, and counsel
for Governor Mead did accept service of the subpoena in the late afternoon on October
10, 2014.
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imposing a hardship on them and the people around them. This is even more true for the
Governor of a state and the citizens who have made their way onto his busy schedule. In
fact, Governor Mead has multiple preexisting commitments that make it nearly
impossible for him to attend the hearing. Mead Aff. at 3. On the night before the
hearing Governor Mead will be in Cheyenne for a long scheduled Industry Roundtable
Reception and Dinner with many attendees who are traveling from out of state for the
event. Id. The following day, in addition to a host of other meetings and duties, he is
scheduled to travel from Cheyenne to Riverton for a gubernatorial debate. Id. These
debates are scheduled long in advance and cannot be rescheduled. Id. Governor Mead
cannot attend the hearing as commanded by the subpoena without significantly disrupting
the plans of a host of different individuals and potentially missing the debate. Id.
6. Accordingly, at a minimum, the subpoena should be quashed for failing to
allow Governor Mead a reasonable time to comply. Moreover, and more importantly, the
subpoena should be quashed because it imposes an undue burden on Governor Mead to
require his testimony at a hearing where he has no personal knowledge of any of the facts
likely to be at issue. Mead Aff. at 4.
7. In evaluating a motion to quash a subpoena, the district court may consider
whether (i) the subpoena was issued primarily for purposes of harassment, (ii) there are
other viable means to obtain the same evidence, and (iii) to what extent the information
sought is relevant, nonprivileged, and crucial to the moving party's case. Bogosian v.
Woloohojian Realty Corp., 323 F.3d 55. 66 (1st Cir.2003). The Court may quash or
modify a subpoena that is unreasonable on the basis of annoyance, embarrassment,
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oppression, or undue burden or expense or seeks privileged or otherwise protected
information. Meacham v. Church, 2010 WL 1576711, at *2 (D. Utah April 19, 2010).
The Court also considers whether the information is necessary and available from any
other source. Id.(quoting 9A Fed. Prac. & Proc. Civ. 2463.1).
8. These same considerations are at issue when a party has subpoenaed a
government employee to testify. When a government employee is subpoenaed, the court
must determine whether it would be an undue burden for the government to produce [the
employee] and to weigh that burden against the Plaintiffs need for the testimony.
Solomon v. Nassau County, 274 F.R.D. 455, 458 (E.D.N.Y. 2011). [] Department heads
and similarly high-ranking officials should not ordinarily be compelled to testify unless it
has been established that the testimony to be elicited is necessary and relevant and
unavailable from a lesser ranking officer. Halderman v. Pennhurst State Sch. &
Hosp., 96 F.R.D. 60, 64 (E.D. Pa. 1982) (citing Sneaker Circus, Inc. v. Carter, 457 F.
Supp. 771, 794 n. 33 (E.D.N.Y.1978) (emphasis added); United States v. Northside
Realty Assoc., 324 F. Supp. 287, 293 (N.D. Ga. 1971)). Because [h]igh ranking
government officials have greater duties and time constraints than other witnesses ...
[they] should not, absent extraordinary circumstances, be called to testify regarding
their reasons for taking official actions. In re U.S., 197 F.3d 310, 313 (8th Cir. 1999)
(citations and internal quotations omitted) (emphasis added).
9. In this case, Governor Mead has no necessary or relevant information to
offer on any of the four factors the Court must consider at the hearing on the motion for
preliminary injunction. Neither Governor Mead, nor any member of his staff, are
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11. The same reasoning holds true in this case. Governor Mead does not make
the decision to grant or deny marriage licenses in Wyoming, does not have any authority
over the individuals who make these decisions, and he does not determine who is or is
not eligible for any particular state benefit. As a result, he has no facts to offer the Court
on any of the four factors at issue in these preliminary injunction proceedings.
Accordingly, it would be an undue burden on him to testify in these proceedings, and the
subpoena should be quashed.
12. Moreover, the Court can infer from the Governors lack of personal
knowledge and the manner and timing of service that the subpoena was issued primarily
for the purposes of harassment and annoyance. The Attorney Generals Office routinely
accepts service of process for the State, its officers, and agencies, and most certainly
would have done so in this case, had it been given the opportunity. There is simply no
need for and no excuse for approaching the Governor immediately before a debate
without first seeking to secure an acceptance of service from counsel. Similarly, there is
no legitimate reason for attempting to elicit the testimony of the Governor in this matter,
particularly where doing so would disrupt his ability to participate in a gubernatorial
debate.
13. In conformity with U.S.D.C.L.R. 7.1 counsel for Governor Mead conferred
with counsel for the Plaintiffs about this motion on October 10-11, 2014, but the parties
were unable to resolve their dispute. Plaintiffs did offer to attempt to arrange either a
video deposition or a video conference to allow Governor Mead to testify at the hearing,
but that offer is neither reasonable nor appropriate. Neither suggestion cures the untimely
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notice or addresses the fact that Governor Meads schedule is already full. More
importantly, even if the notice had not been untimely, Governor Mead still has no factual
information to offer at the hearing and this subpoena appears calculated merely to harass
and annoy the Governor right before an important debate.
WHEREFORE Governor Mead requests that the Court quash the subpoena
commanding his attendance at the hearing on Plaintiffs Motion for Preliminary
Injunction.
Dated this 13th
day of October, 2014.
OFFICE OF THE ATTORNEY GENERAL
/s/James C. Kaste
Peter K. Michael, (Wyo. Bar. No. 5-2309)
Attorney General of Wyoming
Martin L. Hardsocg (Wyo. Bar No. 6-2919)
Deputy Attorney General
James C. Kaste, (Wyo. Bar No. 6-3244)
Deputy Attorney GeneralJared S. Crecelius (Wyo. Bar No. 6-4118)
Senior Assistant Attorney General
Ryan T. Schelhaas (Wyo. Bar No. 6-3321)
Senior Assistant Attorney General
Michael M. Robinson (Wyo. Bar. No. 6-2658)
Senior Assistant Attorney General
Attorneys for the State Defendants
123 State Capitol Building
Cheyenne, WY 82002
(307) 777-7876
(307) 777-3687 fax
pete.michael@wyo.gov
marty.hardsocg@wyo.gov
james.kaste@wyo.gov
jared.crecelius@wyo.gov
ryan.schelhaas@wyo.gov
mike.robinson@wyo.gov
Case 2:14-cv-00200-SWS Document 18 Filed 10/13/14 Page 8 of 9
mailto:pete.michael@wyo.govmailto:pete.michael@wyo.govmailto:marty.hardsocg@wyo.govmailto:marty.hardsocg@wyo.govmailto:james.kaste@wyo.govmailto:james.kaste@wyo.govmailto:jared.crecelius@wyo.govmailto:jared.crecelius@wyo.govmailto:ryan.schelhaas@wyo.govmailto:ryan.schelhaas@wyo.govmailto:mike.robinson@wyo.govmailto:mike.robinson@wyo.govmailto:mike.robinson@wyo.govmailto:ryan.schelhaas@wyo.govmailto:jared.crecelius@wyo.govmailto:james.kaste@wyo.govmailto:marty.hardsocg@wyo.govmailto:pete.michael@wyo.gov8/11/2019 2:14-cv-00200 #18
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I certify that on this 13th day of October, 2014, I electronically filed the foregoing
with the CM/ECF system which sent notice to the following:
Tracy L. Zubrod James Lyman
zubrod@aol.com Thomas W. Stoever, Jr.
james.lyman@aporter.com
Qusair Mohamedbhai Shannon P. Minter
qm@rmlawyers.com Christopher F. Stoll
sminter@nclrights.org
/s/James C. Kaste
James C. Kaste
Case 2:14-cv-00200-SWS Document 18 Filed 10/13/14 Page 9 of 9
mailto:zubrod@aol.commailto:zubrod@aol.commailto:james.lyman@aporter.commailto:james.lyman@aporter.commailto:qm@rmlawyers.commailto:qm@rmlawyers.commailto:sminter@nclrights.orgmailto:sminter@nclrights.orgmailto:sminter@nclrights.orgmailto:qm@rmlawyers.commailto:james.lyman@aporter.commailto:zubrod@aol.com8/11/2019 2:14-cv-00200 #18
10/17
EXHIBIT
Case 2:14-cv-00200-SWS Document 18-1 Filed 10/13/14 Page 1 of 3
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I
t\0
.
8
( lev. IUI3)
SubpocM
to
Appear nnd
Temlfy nl
"Hearing orTrlalln a Civil Action
UNITED STATES DISTRICT OURT
for the
District
of Wyoming
.. .--..b n.e
Marie Guzzo et
al.
)
Plalnli.ff
)
v )
Civil Action No. 14-cv-00200SWS
M ~ l i D _ e Y _ t : . M e a d , Governor of Wyoming et ?..h._. )
Defendam )
SUBPOENA
TO APPEAR AND TESTIFY
AT
A
HEARING
OR TRIAL IN A CIVIL ACTION
To: Governor
Matthew
H. Mead
-----------. . . N.,. , . .a_m_e .. if ...pe.-rs-on_t_o
,' ' 'vlr,.....om..--,.th.,..fs-.subpo-en-a ':'ls-d:-:-ire-c-ted)-::-----------
YOU ARE COMMANDED to
appear
in the
United
States
district
court at the
time,
date
1
and
place
set
forth below
to
testIfy
at a
hearing
or trial
in
this
civil action.
When you
arrive,
you
must remain at the court
until
the
judge or
a
court
officet allows you to leave.
lPlace:
Ewing
f.KerrFederal Building
Courtroom No.: 2
1 111 South Wolcott St.
~ ~ ~ - = - " ' : ' " - - - - - - - - - - - - - -
Date
and Time: 10/16/201410:00
am
I
asper
WY
82601-2534
.. ---..
You must also bring with you
the
following documents, electronically stored information, or objects (leaw bftmk If
llll
llf1 11/r:able.J:
The
following
provisions of Fed.
R.
Civ. P. 45 are attached-
Rule
45(c)
1
relating to the
place
of
o m p l i a n c e ~
Rule 45(d), relating to your protection as a
person
subject
to
a subpoena; and
Rule
45(e)
and (g),
relating to your
duty
to
respond to
this subpoena
and
the
potential consequences ofnot
doing
so.
()ale:
10/09/2014
CLERK OF COURT
OR
S gtte1111re ofClerk
or
Deputy Clerk
The
name, address.
address,
and
telephone
number
of
the
attorney
representing
name
()jpal ly)
All
Plaintiffs
Anne
Marie
Guzzo, et al. , who issues
or
requests this subpoena, are:
L James Lyman;
ARNOLD
& PORTER LLP; 370
Seventeenth Street,
Suite 4400,
Denver,
Colorado 60202-1370;
Telephone:
(303) 8 6 3 ~ 1 0 0 0 ; Email: james.lyman@aporter.com
Notice to the person
who
issues or
requests
this subpoena
Ir his subpoena
commands
the
production
of documents, electronically stored i n f o r m t i o n ~ or tangible things,
a notice
nnd n
copy
of the
subpoena must be served
on
each
party
in this
oase before
it
is served
on the person to whom It
is
directed. Fed. R Civ. P
45(a)(4). ,
, 11r muumwu
Case 2:14-cv-00200-SWS Document 18-1 Filed 10/13/14 Page 2 of 3
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;
)
i\0 1\ l I R ~ - v . 12/13) Subpoc:
to p p e ~
and 'l'cstll' f at n f;enringorTrial hu Civil Action (pngc
l)
Federal Rule ()fCivil Procedure 45 (c), (d), (e), nd (g) (Effectiwe 12/1/13)
( ~ ) lAce t l f C o m p i i M n c ~ .
(1) For n
Trln/,
Htnrl11g,
or DtpMitlon. A aubpoeno
mny
command
fllll'l\Un tn
attend ntrinl, heatlng. or deposition only
as
follows:
(t\) within 100 miles ofwht:rc the ptrton rtsidcs,. is employed. or
n:I)Ulnrlv
transacts
b u s i n e s ~
In
person: or
(ll} \Vitllin
till:
statu where the
person
resides.
employed,
or regularly
t r n R l l l \ ~ 1 ~ business lrt
person.
lftllc porson
(I) Is aJlnrty or upmty's
officer;at
(II) eommundud
to attend
a ttinl
nnd would
no' Incur
aubstnntlnl
i:Sfl\)nill.l,
l) Fnr Othl r D/sctJvl ry, A subpocnn
mey
commnnd:
(;\)production ol'ckJcumeniS. e el.'tl'llnicnlly Stot'l:d infhrrnlltlolt.
or
tUilJ ,ihlc things nt
a i ~ ~ C ~ :
within 100 milt:.,
nfwhcte
the person resides, Is
l lllttlnyl tl, nr regularly transncts
business
In
person: 11nd
(ll)fllSflUCiion orprcmlSCl D\
the
prel1l1Ses
to be inspected.
(d)
Pr111attlng a Person
Subject to
a
Subpocllhll'i:nforcemeut.
( )
iiV()/ttlug tl111lm
Bttrtlllll or
Expell.ft:l
Sttnctlont. A p11rty or
attorney
M'Jiilll -lihlc
lor Issuing nnd serving a subpnena m11st ll1kc reli$0nabte
steps
tunvold
Imposing
undue burden or
expense
on 11 plli'SOn s u b j c ~ ' l to the
~ u h ) < l l l \ a , 1'1\u oourt fur Ute district. whcro cotnpllanco is
required
must
.:unucu this
duty and
Impose an appruprintc Sllttetlon-which may Include
l u ~ ' t
unmings
and
n:nsonabh:
attorney'$ fees-on o
party or
atturney
who
f n i l ~
In
oon1ply.
l) C'umm1tntlto
Pt11duce Mnterlnfs
nr Pf lrtrtlt
ltrspectloll,
(,\)
.lppunmnct
Not Rtqulred. Apetron c o m m a n d ~ d to produce
thlcllmcnlll. ch:ctronlcally
stored
intorn1ation. or t"n&ible things, or to
purmltthc
lnspectinn o f p r c m i s ~ : s . need
not
nppear
in
person
at
the
plnoe
or
p r t ~ U e t h m or lnspcetlon unless also c o t n m ~ ~ n c l o d to uppenr ror ndepositlort,
huurin .l. ur trinl.
(\1) Oh}tctlmrs.
Aporno\' oonlmDndc,l to pro
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Peter K. Michael, (Wyo. Bar. No. 5-2309)
Attorney General of WyomingMartin L. Hardsocg (Wyo. Bar No. 6-2919)
Deputy Attorney General
James C. Kaste, (Wyo. Bar No. 6-3244)
Deputy Attorney General
Jared S. Crecelius (Wyo. Bar No. 6-4118)
Senior Assistant Attorney GeneralRyan T. Schelhaas (Wyo. Bar No. 6-3321)
Senior Assistant Attorney General
Michael M. Robinson (Wyo. Bar. No. 6-2658)Senior Assistant Attorney General
Wyoming Attorney Generals Office
123 State Capitol Building
Cheyenne, WY 82002
(307) 777-7876
(307) 777-3687 fax
UNITED STATES DISTRICT COURT
DISTRICT OF WYOMING
Anne Marie Guzzo and Bonnie Robinson; )Ivan Williams and Charles Killion; )
Brie Barth and Shelly Montgomery; )
Carl Oleson and Rob Johnston; and )
Wyoming Equality, )
)
Plaintiffs, )
)
v. ) Civil No. 14-CV-200-SWS
)
Matthew H. Mead, in his official capacity as )the Governor of Wyoming; Dean Fausset, in )
his official capacity as Director of the )
Wyoming Department of Administration and )
Information; Dave Urquidez, in his official )
Capacity as Administrator of the State of )
Wyoming Human Resources Division; and )
Debra K. Lathrop, in her official capacity )
as Laramie County Clerk, )
)
Defendants. )
AFFIDAVIT OF MATTHEW H. MEAD
Matthew H. Mead, being first duly sworn, deposes and states of his own knowledge:
I. I am the Governor of the State of Wyoming and a Defendant in this matter. I
have knowledge of the facts stated herein from my ownpersonal knowledge and am competent
to testify thereto.
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2.
On the evening
o
October
9
2014, five minutes before the scheduled start
o
a
debate between gubernatorial candidates, two unidentified individuals approached my staff and
security detail on the campus
o
Casper College. These individuals attempted to reach me, and
my Deputy Chief
o
Staff received a Subpoena to Appear and Testify at a Hearing or Trial in a
Civil Action. The subpoena commands me to appear and testify at the hearing on Plaintiffs
Motion for Preliminary Injunction and Temporary Restraining Order on October 16, 2014, at
10:00 a.m. in Casper, Wyoming. This subpoena does not allow me a reasonable time to comply,
subjects me to
an
undue burden, and any testimony I might be asked to provide
is
not necessary
or relevant
to
the proceedings before the Court.
3.
As
an initial matter, the subpoena only gives me seven total and five working
days notice
o
the hearing. I have multiple preexisting commitments that make it very
burdensome for
me
to attend the hearing. On the night before the hearing I will be in Cheyenne
for a long scheduled Industry Roundtable Reception and Dinner with attendees who are traveling
from out
o
state for the event. The following day, in addition to a host
o
other meetings and
duties, I am scheduled to travel from Cheyenne to Riverton for a gubernatorial debate. These
debates are scheduled long in advance. I cannot attend the hearing as commanded by the
subpoena without significantly disrupting the plans
o
a host
o
different individuals and
potentially missing the debate.
4.
Moreover, I have no personal knowledge
o
any facts likely to
be
at issue at the
hearing on the Plaintiffs motion for preliminary injunction. I am not responsible for issuing
marriage licenses in Wyoming. Similarly, I have no personal knowledge or control over the
determination
o
eligibility for benefits provided by the State
o
Wyoming to married couples.
These determinations are made by other individuals within the executive branch o government.
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Because information related to my decisions with regard to the defense o Wyoming statutes in
this and other cases is privileged, I do not have any testimony information that would assist the
Court in its resolution o the motion for preliminary injunction.
FURTHER AFFIANT SA YETH NAUGHT.
DATED this 0 day o October, 2014.
_g: r?
Matthew H. Mead
STATE OF WYOMING
COUNTY OF LARAMIE
ss
The foregoing AFFIDAVIT OF MATTHEW H MEAD was subscribed and sworn to
before me by Matthew H Mead this _jQ_ day
o
October, 2014.
Witness my hand and official seal.
My Commission Expires:
J/ /
3
{J G
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UNITED STATES DISTRICT COURT
DISTRICT OF WYOMING
Anne Marie Guzzo and Bonnie Robinson; )Ivan Williams and Charles Killion; )
Brie Barth and Shelly Montgomery; )
Carl Oleson and Rob Johnston; and )
Wyoming Equality, )
)
Plaintiffs, )
)
v. ) Civil No. 14-CV-200-SWS
)
Matthew H. Mead, in his official capacity as )the Governor of Wyoming; Dean Fausset, in )
his official capacity as Director of the )
Wyoming Department of Administration and )
Information; Dave Urquidez, in his official )
Capacity as Administrator of the State of )
Wyoming Human Resources Division; and )
Debra K. Lathrop, in her official capacity )
as Laramie County Clerk, )
)
Defendants. )
ORDER GRANTING GOVERNOR MEADS MOTION TO QUASH SUBPOENA
THIS MATTER, having come before the Court on Governor Meads Motion to
Quash Subpoena, and this Court having reviewed the motion and being fully advised in
the premises,
IT IS HEREBY ORDERED that for the reasons set forth in the motion, Governor
Meads Motion to Quash Subpoena is granted, the subpoena is quashed, and Governor
Mead is relieved of any obligation to comply with the subpoena.
DATED this ____ day of October, 2014.
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______________________________________
Scott W. Skavdahl
United States District Judge
Peter K. Michael, (Wyo. Bar. No. 5-2309)
Attorney General of Wyoming
Martin L. Hardsocg (Wyo. Bar No. 6-2919)
Deputy Attorney General
James C. Kaste, (Wyo. Bar No. 6-3244)Deputy Attorney General
Jared S. Crecelius (Wyo. Bar No. 6-4118)
Senior Assistant Attorney General
Ryan T. Schelhaas (Wyo. Bar No. 6-3321)Senior Assistant Attorney General
Michael M. Robinson (Wyo. Bar. No. 6-2658)
Senior Assistant Attorney General
Wyoming Attorney Generals Office
123 State Capitol BuildingCheyenne, WY 82002
(307) 777-7876
(307) 777-3687 fax
Case 2:14-cv-00200-SWS Document 18-3 Filed 10/13/14 Page 2 of 2