United States of America v. State of California et al

Filing 10

PROPOSED BRIEFING SCHEDULE by Plaintiff United States of America re: 2 Motion for Preliminary Injunction (Attachments: # 1 Proposed Order)(Reuveni, Erez) Modified on 3/9/2018 (Donati, J).

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CHAD A. READLER
Acting Assistant Attorney General
MCGREGOR SCOTT
United States Attorney
AUGUST FLENTJE
Special Counsel
WILLIAM C. PEACHEY
Director
EREZ REUVENI
Assistant Director, Office of Immigration Litigation
U.S. Department of Justice, Civil Division
P.O. Box 868, Ben Franklin Station
Washington, DC 20044
Tel. [phone]
[e-mail]
DAVID SHELLEDY
Civil Chief, Assistant United States Attorney
LAUREN C. BINGHAM
JOSEPH A. DARROW
JOSHUA S. PRESS
Trial Attorneys
Attorneys for the United States

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UNITED STATES DISTRICT COURT

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EASTERN DISTRICT OF CALIFORNIA

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THE UNITED STATES OF AMERICA,
No. 2:18-cv-00490-JAM-KJN
Plaintiff,
v.
PLAINTIFF’S PROPOSED SCHEDULE
ON BRIEFING AND ARGUMENT FOR
THE MOTINO FOR PRELIMNARY
INJUNCTION

THE STATE OF CALIFORNIA;
EDMUND GERALD BROWN JR.,
Governor of California, in his Official
Capacity; and XAVIER BECERRA,
Attorney General of California, in his
Official Capacity,
Defendants.

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Pursuant to the Court’s order issued March 7, 2018 (ECF 7), the United States submits this

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statement and proposed schedule for further briefing and argument on the pending motion for

Plaintiff’s Notice of Possibly Related Case

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preliminary injunction.

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Counsel for Plaintiff conferred with counsel for Defendants, Satoshi Yanai, Anthony Hakl,

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and Lee Sherman on March 9, 2018 by telephone. Defendants indicated they would not agree to a

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proposed schedule for the pending motion, but instead sought the United States’ position on a

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schedule for unrelated motion practice concerning motions that Defendants suggested they may,

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but have not yet, filed with the Court. Should Defendants file such motions, the United States will

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respond at that time, but as concerns the Court’s order on scheduling, the United States proposed

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to Defendants and proposes to this Court the following schedule:

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March 23, 2018: deadline for any amicus filings in support of Plaintiff

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March 30, 2018: deadline for Defendants’ opposition to the motion for preliminary

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injunction

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April 9, 2018: deadline for any amicus filings in support of Defendants

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April 16, 2018: deadline for Plaintiff’s reply in support of the motion for preliminary

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injunction

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

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April 24 or May, 1 2018, or another date convenient to the Court: oral argument
Plaintiff believes this proposed schedule provides an appropriate amount of time to the

parties and any potential amici to submit appropriate pleadings and for this Court to consider those

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pleadings before argument. Accordingly, the United States respectfully requests that the Court
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issue an order entering the schedule proposed in this filings.

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//

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//

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DATED: March 9, 2018

Plaintiff’s Notice of Possibly Related Case

CHAD A. READLER
Acting Assistant Attorney General

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MCGREGOR SCOTT
United States Attorney

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AUGUST FLENTJE
Special Counsel

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WILLIAM C. PEACHEY
Director

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/s/ Erez Reuveni
EREZ REUVENI
Assistant Director
U.S. Department of Justice, Civil Division
Office of Immigration Litigation
P.O. Box 868, Ben Franklin Station
Washington, DC 20044
Telephone: [phone]
Fax: [phone]
E-mail: [e-mail]

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DAVID SHELLEDY
Civil Chief, Assistant United States
Attorney

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LAUREN C. BINGHAM
JOSEPH A. DARROW
JOSHUA S. PRESS
Trial Attorneys

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Attorneys for Plaintiff

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CERTIFICATE OF SERVICE

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Plaintiff’s Notice of Possibly Related Case

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I hereby certify that on March 9, 2018, I electronically transmitted the attached document

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to the Clerk’s Office using the U.S. District Court for the Eastern District of California’s

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Electronic Document Filing System (ECF). Pursuant to the consent of Defendants’ counsel, I

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hereby certify I have am serving this document to Satoshi Yanai, Anthony Hakl, and Lee

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Sherman via email, as counsel for Defendants have not yet noticed an appearance.

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/s/ Erez Reuveni
EREZ REUVENI
Assistant Director

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Plaintiff’s Notice of Possibly Related Case

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