STATE OF WISCONSIN CIRCUIT COURT ST. CROIX COUNTY

TOWN OF FOREST,

Petitioner,Case No.: 14-CV-18
Class Code: 30607
v.(Administrative Agency Review)

PUBLIC SERVICE COMMISSION OF WISCONSIN,

Respondent.

NOTICE OF MOTION AND MOTION FOR NON-SUMMARY REMEDIAL CONTEMPT OF COURT

To:Public Service Commission of Wisconsin
Andrew Cardon and Jim Lepinski
610 North Whitney Way, PO Box 7854
Madison, WI 53707

Highland Wind Farm
Jordan J Hemaidan
Michael Best & Friedrick LLP
One South Pinckney Street Ste 700
Madison, WI 53703

PLEASE TAKE NOTICE that the Petitioner in this action, the Town of Forest, by its undersigned counsel, submits a Motion for Non-Summary Remedial Contempt of Court against the Respondent, Public Service Commission of Wisconsin, for failure to abide by a Decision and Order rendered by the Court, pursuant to Wis. Stat. 785.03(1)(a).

MOTION FOR NON-SUMMARY REMEDIAL CONTEMPT OF COURT
Petitioner Town of Forest, by its undersigned counsel, hereby moves the Court to find the Respondent, Public Service Commission of Wisconsin, in contempt of court for failure to abide by the terms of this Courts Decision and Order. Petitioner specifically moves the Court for a non-summary and remedial sanction compelling Respondent to amend its Final Decision on Remand to include the noise protections extended to the six sensitive residences identified in the Courts Decision and Order, pursuant to Wis. Stat. 785.03(1)(a). The factual and legal grounds for this motion for non-summary remedial contempt of court are set forth in the accompanying Petitioners Memo in Support of Motion for Non-Summary Remedial Contempt of Court, which is being simultaneously filed.
Dated this 9th day of September, 2016.

Respectfully submitted,
LEVINE LYON LLP

____________________________
By:Jeremy B. Lyon, SBN 1094374
Attorney for the Town of Forest
Levine Lyon LLP
14 West Mifflin Street, Suite 206
Madison, WI 53703
(888) 367-8198 (Telephone)
(608) 268-8607 (Facsimile)
jeremy@levinelyon.com