Perry et al v. Schwarzenegger et al

Filing 266

STIPULATION and [Proposed] Order To Extend Time Regarding Pretrial Filings by Paul T. Katami, Kristin M. Perry, Sandra B. Stier, Jeffrey J. Zarrillo. (Attachments: #1 Affidavit Declaration of Sarah E. Piepmeier)(Piepmeier, Sarah) (Filed on 11/30/2009)

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Gibson, Dunn & Crutcher LLP

GIBSON, DUNN & CRUTCHER LLP Theodore B. Olson, SBN 38137 [e-mail] Matthew D. McGill, pro hac vice Amir C. Tayrani, SBN 229609 1050 Connecticut Avenue, N.W., Washington, D.C. 20036 Telephone: [phone], Facsimile: [phone] Theodore J. Boutrous, Jr., SBN 132009 [e-mail] Christopher D. Dusseault, SBN 177557 Ethan D. Dettmer, SBN 196046 Sarah E. Piepmeier, SBN 227094 Theane Evangelis Kapur, SBN 243570 Enrique A. Monagas, SBN 239087 333 S. Grand Avenue, Los Angeles, California 90071 Telephone: [phone], Facsimile: [phone] BOIES, SCHILLER & FLEXNER LLP David Boies, pro hac vice [e-mail] Theodore H. Uno, SBN 248603 333 Main Street, Armonk, New York 10504 Telephone: [phone], Facsimile: [phone] Attorneys for Plaintiffs KRISTIN M. PERRY, SANDRA B. STIER, PAUL T. KATAMI, and JEFFREY J. ZARRILLO UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA KRISTIN M. PERRY, SANDRA B. STIER, PAUL T. KATAMI, and JEFFREY J. ZARRILLO, Plaintiffs, v. ARNOLD SCHWARZENEGGER, in his official capacity as Governor of California; EDMUND G. BROWN, JR., in his official capacity as Attorney General of California; MARK B. HORTON, in his official capacity as Director of the California Department of Public Health and State Registrar of Vital Statistics; LINETTE SCOTT, in her official capacity as Deputy Director of Health Information & Strategic Planning for the California Department of Public Health; PATRICK O'CONNELL, in his official capacity as Clerk-Recorder for the County of Alameda; and DEAN C. LOGAN, in his official capacity as Registrar-Recorder/County Clerk for the County of Los Angeles, Defendants.
09-CV-2292 VRW STIPULATION AND [PROPOSED] ORDER REGARDING RULE 26 DISCLOSURES

CASE NO. 09-CV-2292 VRW STIPULATION AND [PROPOSED] ORDER REGARDING RULE 26 DISCLOSURES

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Gibson, Dunn & Crutcher LLP

WHEREAS, the parties met and conferred repeatedly on case management issues and submitted extensive case management statements in advance of the Court's August 19, 2009 case management conference; and WHEREAS, on August 19, 2009, the Court issued an order setting November 30, 2009 as the deadline for the parties to complete discovery in this case, and, accordingly, the parties immediately began serving and responding to discovery; and WHEREAS, the parties believe that the initial disclosures required by Federal Rule of Civil Procedure 26 have been or will be made through the course of the expedited discovery process; and WHEREAS, given the parties' continuing efforts to complete discovery by the deadline set by the Court, the parties believe that the initial disclosures required by Federal Rule of Civil Procedure 26 have been or will be made through the course of the expedited discovery process. NOW, THEREFORE, the parties, through their respective counsel of record, hereby stipulate and agree, and ask the Court to enter an order pursuant to Federal Rule of Civil Procedure 26(f)(1) as follows: 1. No Party is required to provide initial disclosures pursuant to Federal Rule of Civil

Procedure 26(a)(1); 2. 3. The parties are not required to file a separate report pursuant to Rule 26(f)(2); and If the Court later determines that Rule 26 disclosures should be made or a separate

Rule 26 report should be filed, the parties will meet and confer and will exchange Rule 26 disclosures and file a separate Rule 26 report within 10 days of the Court's direction. DATED: November 25, 2009 GIBSON, DUNN & CRUTCHER LLP By: and BOIES, SCHILLER & FLEXNER LLP David Boies Attorneys for Plaintiffs KRISTIN M. PERRY, SANDRA B. STIER, PAUL T. KATAMI, and JEFFREY J. ZARRILLO 1
09-CV-2292 VRW STIPULATION AND [PROPOSED] ORDER REGARDING RULE 26 DISCLOSURES

/s/ Ethan Dettmer

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Gibson, Dunn & Crutcher LLP

DATED: November 12, 2009

OFFICE OF THE CITY ATTORNEY By: /s/ Ronald Flynn

Attorneys for Plaintiff-Intervenor CITY AND COUNTY OF SAN FRANCISCO DATED: November 10, 2009 COOPER AND KIRK, PLLC By: /s/ Nicole Moss

Attorneys for Defendant-Intervenors PROPOSITION 8 OFFICIAL PROPONENTS; and PROTECTMARRIAGE.COM ­ YES ON 8, A PROJECT OF CALIFORNIA RENEWAL DATED: November 9, 2009 OFFICE OF THE ATTORNEY GENERAL By: /s/ Tamar Pachter

Attorneys for Defendant ATTORNEY GENERAL EDMUND G. BROWN, JR. DATED: November 12, 2009 MENNEMEIER, GLASSMAN & STROUD LLP By: /s/ Kenneth C. Mennemeier

Attorneys for Defendants ARNOLD SCHWARZENEGGER, MARK B. HORTON, and LINETTE SCOTT (the "Administration Defendants") DATED: November 12, 2009 THE OFFICE OF THE COUNTY COUNSEL By: /s/ Manuel F. Martinez

Attorneys for Defendant PATRICK O'CONNELL, Clerk-Recorder for the County of Alameda DATED: September 9, 2009 THE OFFICE OF COUNTY COUNSEL By: /s/ Judy Whitehurst

Attorneys for Defendant DEAN C. LOGAN, Recorder/County Clerk for the County of Los Angeles 2
09-CV-2292 VRW STIPULATION AND [PROPOSED] ORDER REGARDING RULE 26 DISCLOSURES

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Gibson, Dunn & Crutcher LLP

ORDER PURSUANT TO STIPULATION, IT IS SO ORDERED.

Dated:_____________________

______________________________________ HON. VAUGHN R. WALKER United States District Chief Judge

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09-CV-2292 VRW STIPULATION AND [PROPOSED] ORDER REGARDING RULE 26 DISCLOSURES

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Gibson, Dunn & Crutcher LLP

ATTESTATION PURSUANT TO GENERAL ORDER NO. 45 Pursuant to General Order No. 45 of the Northern District of California, I attest that concurrence in the filing of the document has been obtained from each of the other signatories to this document.

By: /s/ Enrique A. Monagas Enrique A. Monagas

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09-CV-2292 VRW STIPULATION AND [PROPOSED] ORDER REGARDING RULE 26 DISCLOSURES