This document is a motion filed by the plaintiffs' attorneys requesting permission from the court to file a fourth amended complaint. Specifically, the motion requests: (1) changing the class definition; (2) removing Michele Reinhart as a plaintiff and adding George and Susie Pfau; and (3) adding claims against additional defendants including Central Asia Institute and MC Consulting for alleged RICO violations. The motion also details why the plaintiffs' counsel believes the additional claims and parties are necessary.

1. Alexander (Zander) Blewett, III
Anders Blewett
HOYT & BLEWETT PLLC
501 Second Avenue North
P.O. Box 2807
Great Falls, MT 59403-2807
Phone: (406) 761-1960
Fax: (406) 761-7186
E-mail: zblewett@hoytandblewett.com
ablewett@hoytandblewett.com
Larry D. Drury
LARRY D. DRURY, LTD.
100 N. LaSalle Street, Ste. 1010
Chicago, IL 60602
Phone: (312) 346-7950
Fax: (312) 346-5777
E-mail: ldrurylaw@aol.com
Robert A. Langendorf
ROBERT A. LANGENDORF, P.C.
134 N. LaSalle Street, Ste. 1515
Chicago, IL 60602
Phone: (312) 782-5933
Fax: (312) 371-1771
E-mail: rlangendorf@comcast.net
Attorneys for Plaintiffs
IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF MONTANA
MISSOULA DIVISION
* * * * * * * * * * * * * * * * * * * * *
MICHELE REINHART, )
DAN DONOVAN, and )
DEBORAH NETTER, individually )
and on behalf of all others similarly )
situated, )
)
Plaintiffs, )
)
v. )
)
GREG MORTENSON, DAVID )
OLIVER RELIN, PENGUIN )
GROUP (USA), INC., a Delaware )
Corporation, and MC CONSULTING, )
INC., a Montana Corporation, )
)
Defendants. )
Cause No. CV-11-72-M
Judge: Sam E. Haddon
PLAINTIFFS’ MOTION TO FILE
FOURTH AMENDED
COMPLAINT PURSUANT TO
RULE 15 F.R.Civ.P., and MOTION
TO DROP AND ADD PARTIES,
PURSUANT TO RULE 21
F.R.CIV.P.
* * * * * * * * * * * * * * * * * * * * *
Case 9:11-cv-00072-SEH Document 112 Filed 11/30/11 Page 1 of 4

2. COME NOW the Plaintiffs and move this Court for an order granting leave,
pursuant to Rule 15, F.R.Civ.P., to file a Fourth Amended Complaint for Class
Action with Demand for Jury Trial and to drop Michele Reinhart as a party
Plaintiff and to add George and Susie Pfau as party Plaintiffs, pursuant to Rule 21,
F.R.Civ.P.
The purposes for which Plaintiffs move the Court for an order granting
leave to file the Fourth Amended Complaint are as follows:
1. To change the definition of the class to include those purchasers of
the two books in the U.S., excluding Montana Federal Judges and their immediate
family members.
2. To drop Plaintiff, Michele Reinhart, as a party Plaintiff and to add
George and Susie Pfau as party Plaintiffs.
3. Further investigation into this case has allowed Plaintiffs to discover
they have claims against Greg Mortenson, David Oliver Relin (Relin), Penguin
Group (USA), Inc. (Penguin), Central Asia Institute (CAI) and MC Consulting,
Inc. (MC), for RICO violations, pursuant to 18 U.S.C. § 1962(c) and (d). Counts I
and II of the Fourth Amended Complaint set forth these claims based on RICO
violations. This further investigation has reflected that CAI was a participant in
the enterprise which committed the RICO violations and that CAI should be a
party Defendant in this case, not for the original reason brought by Jean Price, a
donor, but because of CAI’s involvement in the RICO violations as a member of
the enterprise. The RICO violations create federal question jurisdiction for this
Court, pursuant to 28 U.S.C. § 1331, in addition to federal question jurisdiction
under 28 U.S.C. § 1332(d), the class action federal question. Furthermore, the
RICO claims, predicated on mail fraud and wire fraud, do not require that every
purchaser who is a member of the class specifically rely on the enterprise’s mail
fraud and wire fraud.
-2-
Case 9:11-cv-00072-SEH Document 112 Filed 11/30/11 Page 2 of 4

3. 4. Further investigation has shown the involvement of CAI in Plaintiffs’
fraud claim (Count V), deceit claim (Count VI), unjust enrichment claim (Count
VII), accounting and injunctive relief claim (Count XI), and the class action
allegations (Count XII) and, therefore, it is necessary to add CAI as a party
Defendant in such Counts.
Plaintiffs’ counsel requested all defense counsel to consent to the filing of
an amended complaint to change the definition of the class. This occurred in
Judge Molloy’s courtroom on September 16, 2011. Counsel for all Defendants
steadfastly refused to so consent. Therefore, Plaintiffs have complied with L.R.
7.1(c)(1). In addition, Plaintiffs’ counsel sent a copy of the proposed Fourth
Amended Complaint to Defendants’ counsel requesting their consent. They did
not consent, claiming they needed more time, even though they had already
refused to consent earlier. In any event, time is of the essence in order to
accommodate Michele Reinhart’s decision to be dropped as a party Plaintiff and to
add George and Susie Pfau as replacement party Plaintiffs.
Plaintiffs’ Fourth Amended Complaint for Class Action and Demand for
Jury Trial is attached hereto as Exhibit “A”. This Motion has been supported by a
brief filed herewith.
DATED this 30th
day of November, 2011.
HOYT & BLEWETT PLLC
/s/ Alexander Blewett, III
Alexander (Zander) Blewett, III
Anders Blewett
Attorneys for Plaintiffs
//
//
//
//
-3-
Case 9:11-cv-00072-SEH Document 112 Filed 11/30/11 Page 3 of 4

4. CERTIFICATE OF SERVICE
I hereby certify that, on this 30th
day of November, 2011, a copy of the
foregoing document was served on the following persons by the following means:
1,2,3,4,5,6,7 CM/ECF
Hand Delivery
Mail
Overnight Delivery Service
Fax
E-Mail
1. Clerk, U.S. District Court
2. John M. Kauffman
Kasting, Kauffman & Mersen, P.C.
716 S. 20th
Avenue, Suite 1010
Bozeman, MT 59718
Attorneys for Def. Mortenson
3. Kevin C. Maclay
Todd E. Phillips
Caplin & Drysdale, Chartered
One Thomas Circle, NW, Ste. 1100
Washington, D.C. 20005
Co-Counsel for Def. Mortenson
4. Jonathan M. Herman
Dorsey & Whitney LLP
51 West 52nd
Street
New York, NY 10019-6119
Attorneys for Def. Penguin
5. F. Matthew Ralph
Dorsey & Whitney LLP
Suite 1500, 50 S. Sixth Street
Minneapolis, MN 55402-1498
Attorneys for Def. Penguin
6. Charles E. Hansberry
Elena J. Zlatnik
Garlington, Lohn & Robinson, PLLP
P.O. Box 7909
Missoula, MT 59807-7909
Attorneys for Def. David Oliver Relin
7. Sonia A. Montalbano
Elliott, Ostrander & Preston, P.C.
Union Bank of California Tower
707 SW Washington St., Ste. 1500
Portland, OR 97205
Attorneys for Def. David Oliver Relin
HOYT & BLEWETT PLLC
/s/ Alexander Blewett, III
Alexander (Zander) Blewett, III
Anders Blewett
Attorneys for Plaintiffs
-4-
Case 9:11-cv-00072-SEH Document 112 Filed 11/30/11 Page 4 of 4