Haynie et al v. City of Pleasanton et al

Filing 58

ORDER continuing 6/29/12 case mgt conference to 7/27/12, Motions terminated: (57 in 3:10-cv-01255-SI) STIPULATION WITH PROPOSED ORDER re: Case Management filed by California Department of Justice, Kamala Harris. Further Case Management Conference set for 7/27/2012 03:00 PM in Courtroom 10, 19th Floor, San Francisco.. Signed by Judge Illston on 6/21/12. (tfS, COURT STAFF) (Filed on 6/21/2012)

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KAMALA D. HARRIS
Attorney General of California
PETER A. KRAUSE
Supervising Deputy Attorney General
ROSS C. MOODY
Deputy Attorney General
State Bar No. 142541
455 Golden Gate Avenue, Suite 11000
San Francisco, CA 94102-7004
Telephone: [phone]
Fax: [phone]
E-mail: [e-mail]
Attorneys for Defendants California Department of
Justice and Attorney General Kamala D. Harris

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IN THE UNITED STATES DISTRICT COURT
FOR THE NORTHERN DISTRICT OF CALIFORNIA
MARK AARON HAYNIE, BRENDAN
JOHN RICHARDS, THE CALGUNS
FOUNDATION, INC., and THE SECOND
AMENDMENT FOUNDATION, INC.,

10-cv-1255-SI
11-cv-2493 SI
(Consolidated Cases)

Plaintiffs, STIPULATION and JOINT
ADMINISTRATIVE MOTION and
v.
PROPOSED ORDER
Re: Case Management
KAMALA HARRIS, Attorney General of
California (in her official capacity) and
CALIFORNIA DEPARTMENT OF
JUSTICE, CITY OF ROHNERT PARK,
OFFICER DEAN BECKER (RP134), and
DOES 1 TO 20,
Defendants.
BRENDAN JOHN RICHARDS, THE
CALGUNS FOUNDATION, INC., and THE 11-cv-5580 SI
SECOND AMENDMENT FOUNDATION, (Related Case)
INC. ,
STIPULATION and JOINT
Plaintiffs, ADMINISTRATIVE MOTION and
PROPOSED ORDER
v.
Re: Case Management
KAMALA HARRIS, Attorney General of
California (in her official capacity),
CALIFORNIA DEPARTMENT OF
JUSTICE, SONOMA COUNTY
SHERIFF'S OFFICE, SHERIFF'S
DEPUTY GREG MYERS (SD1023) and
DOES 1 TO 20
Defendants.

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1
Stipulation/Order: Case Management (10-cv-1255-SI)

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MAX JOSEPH PLOG-HOROWITZ, THE
CALGUNS FOUNDATION, INC., and THE 12-cv-00452 (LB)
SECOND AMENDMENT FOUNDATION, (Related Case)
INC.,
Plaintiffs, STIPULATION and JOINT
ADMINISTRATIVE MOTION and
v.
PROPOSED ORDER
Re: Case Management
KAMALA HARRIS, Attorney General of
California, CALIFORNIA DEPARTMENT
OF JUSTICE, COTATI POLICE
DEPARTMENT, CITY OF COTATI,
ANDREW LYSSAND (CO0339) and DOES
1 TO 20,
Defendants.

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IT IS HEREBY STIPULATED1 by and between the parties hereto through their respective

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attorneys of record that the pending Case Management Conference currently set for June 29, 2012

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in Courtroom 10, 19th Floor of the U.S. District Court for the Northern District of California

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should be reset.
The Defendants in Richards v. Harris I (Rohnert Park), Case No.: 3:11-CV-02493 SI have

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a motion to dismiss under submission that has been fully briefed and was argued on May 4, 2012.

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The parties believe that it would be a more productive use of the Court’s time and resources to

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have the Case Management Conference after a ruling on the motion to dismiss has been issued
Accordingly, the parties propose that the Court reset the Case Management Conference to

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some date after the Court anticipates releasing its order from the May 4, 2012 hearing.

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Haynie v. Harris, Case No.: 3:10-CV-01255 SI was ordered consolidated with Richards
v. Harris, Case No.: 3:11-CV-02493 SI, in an order filed on October 22, 2011. (See Documents #
42 and #15 respectively.) The second Richards v. Harris, Case No.: 3:11-CV-05580 was ordered
to be related with the first two cases in an order filed on December 21, 2011. (See documents #47
and # 20 respectively.) The Ploghorowitz v. Harris, Case No.: 3:12-CV-0452 SI was ordered to
be related on April 11, 2012. (See documents #32 and #20.)
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Stipulation/Order: Case Management (10-cv-1255-SI)

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SO STIPULATED.

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Dated: June 20, 2012

Dated: June 20, 2012

/s/ Ross Moody
________________________________
Ross Moody
Counsel for Defendants
Harris & California Dept. of Justice

/s/ Donald Kilmer
________________________________
Donald Kilmer
Counsel for Plaintiffs

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Dated: June 20, 2012

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/s/ Robert W. Henkels
________________________________
Robert W. Henkels
Counsel for Defendants
City of Rohnert Park & Becker
Counsel for Defendants
Cotati Police Department,
City of Cotati, & Lyssand

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ATTESTATION FOR COMPLIANCE WITH GENERAL ORDER 45 AND LOCAL
RULE VIII.B.
I, Ross C. Moody, declare under penalty of perjury under the laws of California and the

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United States that I have in my possession e-mail correspondence from Donald Kilmer and

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Robert Henkels that the content of this document is acceptable to all persons required to sign the

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document. I declare that this document was signed in San Francisco, CA on June 20, 2012.

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/s/ Ross Moody
________________________________
Ross Moody
Deputy Attorney General
Attorney for Defendants
California Department of Justice and
Attorney General Kamala D. Harris
ORDER

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The Case Management Conference in these consolidated and related matters currently set

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July 27, 2012
3 p.m.
for June 29, 2012 is reset to: (Date) _________________________, at (Time): _____________,

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in Courtroom 10, 19th Floor of the U.S. District Court for the Northern District of California –
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Stipulation/Order: Case Management (10-cv-1255-SI)

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San Francisco. A Joint Case Management Conference Statement shall be filed seven (7) calendar

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days before the new date.

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Date:

6/21/12

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__________________________________
United States District Judge

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SA2010101060
20620461.doc

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Stipulation/Order: Case Management (10-cv-1255-SI)