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5.4. SR 05-17-2010
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5.4. SR 05-17-2010
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seek a stay of, or an injunction prohibiting, enforcement of the 4/2110 Order pending <br />further proceedings in either the district court or this Court once a full and final judgment <br />is rendered." 4/21110 ERL Br. at 14. City responds by arguing that, "[b]y their own <br />terms, however, Rule 62 and 108 will not apply if the Court dismisses the appeal. <br />Therefore, they provide no 'safeguard' in that setting at all (and thus no reason to dismiss <br />the appeal)." 4/28/10 City Opp. Br. at 10. City also suggests that Rule 65 is unavailable <br />because it only "authoriz[es] an injunction which [ERL] must believe the district court <br />would issue against itself." Id. at 11 (italics in original). <br />Contrary to City's argument, Minn. R. Civ. P. 62 expressly provides potential <br />protective measures for City short of a premature appeal. Rule 62.01 provides that "the <br />court may stay the execution of or any proceedings to enforce a judgment pending the <br />disposition of," among other things, a Rule 60 motion for relief from judgment or order. <br />Moreover, Rule 62.06 provides that, "[w]hen a court has ordered a final judgment on <br />some but not all of the claims presented in the action under the conditions stated in Rule <br />54.02, the court may stay enforcement of that judgment until the entering of a subsequent <br />judgment or judgments and may prescribe such conditions as are necessary to secure the <br />benefits thereof to the party in whose favor the judgment is entered provides." Likewise, <br />Rule 65's injunction provisions are plainly available to City, if it can establish the <br />requirements for an injunction. And, of course, the injunction would not be sought <br />"against [the district court] itself." Rather it would be sought against ERL to prohibit <br />11 <br />
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