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

Filing 76

STIPULATION and PROPOSED ORDER for Extension of Time for Defendant Jan Scully to File a Response to Motion for Preliminary Injunction and Motion for Protective Order by Jan Scully. Attorney Cassidy, Terence John added. (Cassidy, Terence)

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ProtectMarriage.com - Yes on 8, a Project of California Renewal et al v. Bowen et al Doc. 76 1 A PROFESSIONAL CORPORATION 2 3 4 5 6 7 Terence J. Cassidy, SBN 99180 Kristina M. Hall, SBN 196794 350 University Ave., Suite 200 Sacramento, California 95825 TEL: 916.929.1481 FAX: 916.927.3706 A tto rn e ys for Defendants JAN SCULLY, in her official capacity U N I T E D STATES DISTRICT COURT 8 E A S T E R N DISTRICT OF CALIFORNIA 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 PORTER * SCOTT ATTO RN EY S 3 5 0 U N I V E R S I T Y A V E ., S U I T E 2 0 0 SAC R AM EN T O , C A 95825 T E L : 9 1 6 . 9 2 9 .1 4 8 1 F A X : 9 1 6 . 9 2 7 .3 7 0 6 PROTECTMARRIAGE.COM - YES ON 8, A PROJECT OF CALIFORNIA RENEWAL; N A T I O N A L ORGANIZATION FOR MARRIAGE CALIFORNIA - YES ON 8, SPONSORED BY NATIONAL ORGANIZATION FOR MARRIAGE, JOHN DOE #1, an individual and as representative of the CLASS OF MAJOR DONORS, Plaintiffs, vs. DEBRA BOWEN, Secretary of State for the State of California, in her official capacity; EDMUND G. BROWN, JR., Attorney General for the State of California, in his official capacity; DEAN C. LOGAN, Registrar-Recorder of Los Angeles County, C al i fo rn ia, in his official capacity; DEPARTMENT OF ELECTIONS - CITY AND COUNTY OF SAN FRANCISCO; JAN SCULLY, District Attorney for Sacramento County, California in her official capacity and as a representative of the Class of District Attorneys in the State of California; DENNIS J. HERRERA, City Attorney for the City and County of San Francisco, California, in his official capacity and as a representative of the Class of Elected City Attorneys in the State of California; ROSS JOHNSON, TIMOTHY HODSON, EUGENE HUGUENIN, JR., ROBERT LEIDIGH and RAY REMY, members of the California Fair Political Practices Commision, in their official capacities, Defendants. / 1 C a s e No. 2:09-CV-00058-MCE-DAD S T I P U L A T I O N TO FOR EXTENSION O F TIME FOR DEFENDANT JAN S C U L L Y TO FILE A RESPONSE TO M O TION FO R PRELIM INARY I N J U N C T I O N AND MOTION FOR PROTECTIVE ORDER; ORDER THEREON STIPULATION FOR EXT. OF TIME TO FILE RESPONSE; ORDER REGARDING SAME 00647820.WPD w w w . p o r ter s c o t t . c o m 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 IT IS HEREBY STIPULATED and agreed by and between Plaintiffs P R O T E C T M A R R IA G E .C O M - YES ON 8, A PROJECT OF CALIFORNIA RENEWAL; N A T IO N A L ORGANIZATION FOR MARRIAGE CALIFORNIA - YES ON 8, S P O N S O R E D BY NATIONAL ORGANIZATION FOR MARRIAGE, JOHN DOE #1, an in d iv id u a l and as representative of the CLASS OF MAJOR DONORS and Defendant JAN S C U L L Y , District Attorney for Sacramento County, California in her official capacity, by a n d through their respective undersigned counsel, that the time for Defendant SCULLY to f ile a response to the Plaintiffs' Motion for Preliminary Injunction and Motion for Protective O rd e r shall be extended up to and including 4:00 p.m. on January 23, 2009. T h is Stipulation is being submitted on the grounds that counsel for Defendant S C U L L Y was only retained on January 22, 2009, which is the same day that this Opposition w a s due to be filed and therefore counsel for SCULLY has not had sufficient time to prepare a n Opposition. This request is for a one-day extension and is the first extension requested. Therefore, the request for additional time is based on demonstrated good cause. R e s p e c tf u lly submitted, Dated: January 22, 2009 A L L IA N C E DEFENSE FUND By /s/Scott F. Bieniek Scott F. Bieniek A tto rn e y for Plaintiffs P R O T E C T M A R R IA G E .C O M - YES ON 8 , A PROJECT OF CALIFORNIA RENEWAL; NATIONAL O R G A N IZ A T IO N FOR MARRIAGE CALIFORNIA - YES ON 8, SPONSORED BY NATIONAL O R G A N IZ A T IO N FOR MARRIAGE, J O H N DOE #1, an individual and as re p re s e n ta tiv e of the CLASS OF MAJOR DONORS Dated: January 22, 2009 P O R T E R SCOTT A PROFESSIONAL CORPORATION By 26 27 28 PORTER * SCOTT ATTO RN EY S 3 5 0 U N I V E R S I T Y A V E ., S U I T E 2 0 0 SAC R AM EN T O , C A 95825 T E L : 9 1 6 . 9 2 9 .1 4 8 1 F A X : 9 1 6 . 9 2 7 .3 7 0 6 /s/Terence J. Cassidy Terence J. Cassidy A tto rn e y for Defendant J A N SCULLY, District Attorney for S a c ra m e n to County, California in her o f f ic ia l capacity 2 STIPULATION FOR EXT. OF TIME TO FILE RESPONSE; ORDER REGARDING SAME 00647820.WPD w w w . p o r ter s c o t t . c o m 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 PORTER * SCOTT ATTO RN EY S 3 5 0 U N I V E R S I T Y A V E ., S U I T E 2 0 0 SAC R AM EN T O , C A 95825 T E L : 9 1 6 . 9 2 9 .1 4 8 1 F A X : 9 1 6 . 9 2 7 .3 7 0 6 I T IS SO ORDERED. D a te d : ________________ ___________________________________ U .S . DISTRICT COURT JUDGE 3 STIPULATION FOR EXT. OF TIME TO FILE RESPONSE; ORDER REGARDING SAME 00647820.WPD w w w . p o r ter s c o t t . c o m

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