STATE OF MINNESOTA DISTRICT COURT

COUNTY OF HENNEPIN FOURTH JUDICIAL DISTRICT

Case type: Marital Dissolution
Court File No. 27-FA-11-7451

In Re the Marriage of: )

)
Keith Maurice Ellison, )
)
Petitioner, ) NOTICE OF MOTION AND MOTION
) OF ALPHA NEWS TO INTERVENE
v. ) AND UNSEAL FILE
Kim Dore Ellison, )
)
)
Respondent.
)
)

TO: Carla C. Kjellberg, Kjellberg Law Office, PLLC, 2356 University Avenue West
#230, St. Paul, Minnesota 55114-1850, and Kim Dore Ellison, 2205 Golden Valley Road,
Apt. 204, Minneapolis, MN 55411

PLEASE TAKE NOTICE that Alpha News will move this Court for an order

allowing it to intervene as of right in accordance with Minn. R. Civ. P. 24.01, and for an

order, and for an order granting public and press access to the court files and proceeding

in this case. A more particular state of the grounds for the motion is set forth in the

accompanying Memorandum of Law in Support of Alpha News’ Motion to Intervene and

Unseal Records, which is filed contemporaneously with this motion.

PLEASE TAKE FURTHER NOTICE that the Court may hold a hearing on this

motion at a time and place to be determined.

Dated: September 18, 2018 By: /e/ Nathan M. Hansen
Nathan M. Hansen #0328017
2440 Charles Street North, Ste 242
North St. Paul, MN 55109
651-704-9600
Nathan@hansenlawoffice.com
Attorney for Alpha News