ProtectMarriage.com - Yes on 8, a Project of California Renewal et al v. Bowen et al

Filing 18

EX PARTE APPLICATION by ProtectMarriage.com - Yes on 8, a Project of California Renewal, National Organization for Marriage California - Yes on 8, Sponsored by National Organization for Marriage, John Doe #1 for to Shorten Time for Hearing on Motion for Preliminary Injunction, Motion to Expedite, and Motion for Protective Order and Time to File Opposition and Replies to the Same. (Attachments: # 1 Proposed Order, # 2 Affidavit)(Chandler, Timothy)

ProtectMarriage.com - Yes on 8, a Project of California Renewal et al v. Bowen et al Doc. 18 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 James Bopp, Jr. (Ind. State Bar No. 2838-84)* Barry A. Bostrom (Ind. State Bar No.11912-84)* Sarah E. Troupis (Wis. State Bar No. 1061515)* Scott F. Bieniek (Ill. State Bar No. 6295901)* BOPP, COLESON & BOSTROM 1 South Sixth Street Terre Haute, IN 47807-3510 Telephone: (812) 232-2434 Facsimile: (812) 235-3685 Counsel for All Plaintiffs Timothy D. Chandler (Cal. State Bar No. 234325)** ALLIANCE DEFENSE FUND 101 Parkshore Drive, Suite 100 Folsom, CA 95630 Telephone: (916) 932-2850 Facsimile: (916) 932-2851 Counsel for All Plaintiffs *Pro Hac Vice Application Pending ** Designated Counsel for Service United States District Court Eastern District of California Sacramento Division Case No. 2:09-CV-00058-MCE-DAD ProtectMarriage.com, et al., P l a i nt i f f s , v. Debra Bowen, et al., Defendants. EX PARTE MOTION TO SHORTEN TIME FOR HEARING ON MOTION FOR PRELIMINARY INJUNCTION, MOTION TO EXPEDITE, AND MOTION FOR PROTECTIVE ORDER AND TIME TO FILE OPPOSITION AND REPLIES TO THE SAME Ex Parte Motion to Shorten Time 28 1 Dockets.Justia.com 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 Plaintiffs ProtectMarriage.com - Yes on 8, a Project of California Renewal ("ProtectMarriage.com"), National Organization for Marriage California - Yes on 8, Sponsored by National Organization for Marriage ("NOM-California"), and John Doe #1, an individual, and as a representative of the Class of Major Donors, will and hereby do move to shorten time for hearing on their motion for preliminary injunction, motion to expedite, and motion for protective order and leave to file documents under seal, and time to file opposition and replies to the same. This ex parte motion to shorten time is made pursuant to Local Rule 6-144(d), and on the grounds specified in this motion, and the Affidavit of Sarah E. Troupis filed in support hereof. Plaintiffs hereby move for an order shortening time for hearing, and for the filing of opposition and replies, to Plaintiffs' Motion for Preliminary Injunction, Motion to Expedite, and Motion for Protective Order and Leave to File Documents Under Seal. Plaintiffs propose Monday, January 26, 2009, or Tuesday, January 27, 2009, if available on the Court's calendar, for a hearing on all aforementioned motions. Dated this 9th day of January, 2009. Respectfully submitted, /s/Timothy D. Chandler Timothy D. Chandler (Cal. Bar No. 234325) ALLIANCE DEFENSE FUND 101 Parkshore Drive, Suite 100 Folsom, CA 95630 Counsel for All Plaintiffs Designated Counsel for Service James Bopp, Jr. (Ind. Bar No. 2838-84)* Barry A. Bostrom (Ind. Bar No.11912-84)* Sarah E. Troupis (Wis. Bar No. 1061515)* Scott F. Bieniek (Ill. Bar No. 6295901)* BOPP, COLESON & BOSTROM 1 South Sixth Street Terre Haute, IN 47807-3510 Counsel for All Plaintiffs *Pro Hac Vice Application Pending Ex Parte Motion to Shorten Time 28 2 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 PROOF OF SERVICE I, Timothy D. Chandler, am over the age of 18 years and not a party to the within action. My business address is 101 Parkshore Drive, Suite 100; Folsom, California 95630. On January 9, 2009, I electronically filed the foregoing document described as Ex Parte Motion to Shorten Time for Hearing on Motion for Preliminary Injunction, Motion to Expedite, and Motion for Protective Order and Time to File Opposition and Relies to the Same, which will be served on all Defendants along with the Summons and Amended Complaint. I declare under penalty of perjury under the laws of the State of California that the above is true and correct. Executed on January 9, 2009 at Folsom, California. s/Timothy D. Chandler Timothy D. Chandler (CA Bar No. 234325) Attorney for Plaintiff Ex Parte Motion to Shorten Time 3