Courthouse News Service v. Michael Planet

Filing 61

NOTICE OF MOTION AND MOTION to Dismiss Amended Complaint filed by defendant Michael Planet. Motion set for hearing on 8/4/2014 at 10:00 AM before Judge Manuel L. Real. (Attachments: #1 Memorandum of Points and Authorities ISO Motion to Dismiss, #2 Proposed Order re Motion to Dismiss)(Naeve, Robert)

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Robert A. Naeve (State Bar No. 106095)
[e-mail]
Erica L. Reilley (State Bar No. 211615)
[e-mail]
Nathaniel P. Garrett (State Bar No. 248211)
[e-mail]
JONES DAY
3161 Michelson Drive
Suite 800
Irvine, CA 92612.4408
Telephone: [phone]
Facsimile: +1.949.553.7539
Attorneys for Defendant
MICHAEL PLANET

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UNITED STATES DISTRICT COURT

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CENTRAL DISTRICT OF CALIFORNIA

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WESTERN DIVISION

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COURTHOUSE NEWS SERVICE,

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Plaintiff,
v.
MICHAEL PLANET, IN HIS
OFFICIAL CAPACITY AS COURT
EXECUTIVE OFFICER/CLERK OF
THE VENTURA COUNTY
SUPERIOR COURT,
Defendant.

Case No. CV11-08083 R (MANx)
Assigned for all purposes to
Hon. Manuel L. Real
DEFENDANT’S NOTICE OF
MOTION TO DISMISS
AMENDED COMPLAINT
Date:
Time:
Judge:

August 4, 2014
10:00 a.m.
Hon. Manuel L. Real

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Notice of Motion to Dismiss
Case No. CV 11-08083 R (MANx)

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TO ALL PARTIES AND THEIR ATTORNEYS OF RECORD:

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PLEASE TAKE NOTICE that on August 4, 2014 at 10:00 a.m., or as soon

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thereafter as the matter may be heard in Courtroom 8 of the above-entitled court,

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located at 312 N. Spring St., Los Angeles, California 90012, defendant Michael D.

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Planet, in his official capacity as Executive Officer and Clerk of the Superior Court

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of California, County of Ventura, will and hereby does move the Court to dismiss

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the Amended Complaint on file in this action because it fails to state a claim for

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relief for violation of the First Amendment to the United States Constitution.

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The motion is based on this Notice of Motion, the concurrently filed

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Memorandum of Points and Authorities, all other pleadings and papers filed herein,

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and any additional argument the Court may consider at the hearing on this motion.

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Dated: June 24, 2014.

Respectfully submitted,
JONES DAY

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By: /s/ Robert A. Naeve
Robert A. Naeve
Attorneys for Defendant
MICHAEL PLANET

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Notice of Motion to Dismiss
Case No. CV 11-08083 R (MANx)