Haynie et al v. City of Pleasanton et al

Filing 76

ORDER Further Case Management Conference set for 4/2/13 is continued to 6/21/2013 03:00 PM in Courtroom 10, 19th Floor, San Francisco.. Signed by Judge Susan Illston on 4/1/13., Motions terminated: 75 STIPULATION WITH PROPOSED ORDER to reset CMC filed by Second Amendment Foundation, Inc., Mark Aaron Haynie, Calguns Foundation, Inc., Brendan John Richards.(tfS, COURT STAFF) (Filed on 4/1/2013)

1 Donald E. J. Kilmer, Jr. [SBN: 179986]
LAW OFFICES OF DONALD KILMER
2 1645 Willow Street, Suite 150
San Jose, California 95125
3 Voice: [phone]
Fax: [phone]
4 E-Mail: [e-mail]
5 Jason A. Davis [SBN: 224250]
Davis & Associates
6 30021 Tomas Street, Suite 300
Rancho Santa Margarita, CA 92688
7 Voice: [phone]
Fax: [phone]
8 E-Mail: [e-mail]
9 Attorneys for Plaintiffs
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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.,

Case No.:

3:10-CV-01255 SI

STIPULATION and JOINT
ADMINISTRATIVE MOTION and
PROPOSED ORDER
Re: Case Management

Plaintiffs,

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vs.

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KAMALA HARRIS, Attorney General
of California, CALIFORNIA
DEPARTMENT OF JUSTICE, CITY
OF ROHNERT PARK, and OFFICER
DEAN BECKER (RP134)

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Defendants.

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IT IS HEREBY STIPULATED by and between the parties hereto through

24 their respective attorneys of record that the pending Case Management Conference
25 currently set for April 2, 2013 in Courtroom 10, 19th Floor of the U.S. District Court
26 for the Northern District of California should be reset.
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Donald Kilmer
Attorney at Law
1645 Willow St.
Suite 150
San Jose, CA 95125
Vc: 408/264-8489
Fx: 408/264-8487

The Rohnert Park Defendants and the Plaintiffs are still engaged in earnest

28 self-directed settlement discussions.
CMC Stipulation & Order

Page 1 of 3

Haynie, et al. v. Harris, et al.

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If a settlement can be reached, then the remaining parties (California

2 Department of Justice and the Plaintiffs) will proceed with setting hearing dates for
3 dispositive motions at the next Case Management Conference.
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Furthermore, the Plaintiffs and the California Department of Justice are

5 aware that several bill have been introduced in the State Legislature that may
6 moot this case. Those parties may seek another continuance and/or stay to conserve
7 resources of the parties and the Court.
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The parties propose that the Court reset the Case Management Conference to

9 a convenient date in June of 2013 in order to give the parties engaged in settlement
10 discussions the time necessary to conclude that process or to request formal ADR
11 assistance from the Court.
12 SO STIPULATED.
13 Date: March 26, 2013

Date: March 26, 2013

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/s/
Donald Kilmer
Counsel for Plaintiffs

/s/
Ross Moody,
15 Counsel for Defendants
Harris & California Dept. of Justice
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17 Date: March 26, 2013
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/s/
Robert W. Henkels
19 Counsel for Defendants
City of Rohnert Park & Becker
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ATTESTATION FOR COMPLIANCE WITH GENERAL ORDER 45 AND

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LOCAL RULE VIII.B.

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I, Donald Kilmer, declare under penalty of perjury under the laws of California
and the United States that I have in my possession e-mail correspondence from
25 Ross Moody, and Robert Henkels that the content of this document is acceptable to
all persons required to sign the document. I declare that this document was signed
26 in San Jose, CA on March 26, 2013.
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Donald Kilmer
Attorney at Law
1645 Willow St.
Suite 150
San Jose, CA 95125
Vc: 408/264-8489
Fx: 408/264-8487

/s/
Donald Kilmer
28 Attorney for Plaintiffs
CMC Stipulation & Order

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Haynie, et al. v. Harris, et al.

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ORDER

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The Case Management Conference currently set for April 2, 2013 is reset to:
3:00 p.m.
3 (Date) _____________________________, at (Time): _____________, in Courtroom 10,
6/21/13
4 19th Floor of the U.S. District Court for the Northern District of California – San
5 Francisco. A Joint Case Management Conference Statement shall be filed seven (7)
6 calendar days before the new date.
7 Date: 4/1/13
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United States District Judge

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Donald Kilmer
Attorney at Law
1645 Willow St.
Suite 150
San Jose, CA 95125
Vc: 408/264-8489
Fx: 408/264-8487

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CMC Stipulation & Order

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Haynie, et al. v. Harris, et al.