Quinonez et al v. Does 1 through 5

Filing 68

ORDER granting 67 Stipulation to Reset Hearing Date re 64 , 65 Motions to Dismiss. Motion Hearing reset for 6/21/2023 02:00 PM via Videoconference before Judge William H. Orrick. Signed by Judge William H. Orrick on 05/22/2023. (jmd, COURT STAFF) (Filed on 5/22/2023) Modified on 5/22/2023 to correct time (jmd, COURT STAFF).

Case 3:22-cv-03195-WHO Document 68 Filed 05/22/23 Page 1 of 2

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Jaba Tsitsuashvili (CA Bar No. 309012)
Patrick Jaicomo* (MI Bar No. P-75705)
Trace Mitchell* (DC Bar No. 1780794)
INSTITUTE FOR JUSTICE
901 N. Glebe Road, Suite 900
Arlington, VA 22203
Phone: [phone]
Fax: [phone]
[e-mail]

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*Admitted pro hac vice

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Anna M. Barvir (CA Bar No. 268728)
MICHEL & ASSOCIATES, P.C.
180 E. Ocean Blvd., Suite 200
Long Beach, CA 90802
Phone: [phone]
Fax: [phone]
[e-mail]

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Counsel for Plaintiffs

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United States District Court
Northern District of California

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Case No. 3:22-cv-3195-WHO

RENÉ QUIÑONEZ and
MOVEMENT INK LLC,

STIPULATED REQUEST
TO RESET HEARING DATE OF
PENDING MOTIONS TO DISMISS
[ECF 64, 65]

Plaintiffs,

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Counsel for the United States and the
appearing Individual Defendants

UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF CALIFORNIA
SAN FRANCISCO DIVISION

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ISMAIL J. RAMSEY (CABN 189820)
United States Attorney
MICHELLE LO (NYRN 4325163)
Chief, Civil Division
MICHAEL A. KEOUGH (NYRN 5199666)
Assistant United States Attorney
450 Golden Gate Avenue, Box 36055
San Francisco, California 94102-3495
Telephone: [phone]
Fax: [phone]
[e-mail]

v.
UNITED STATES OF AMERICA; and
JEFF AGSTER, EVA CHAN, STEPHEN
FAJARDO, MARK HODGES, ROBIN LEE,
and DOES 1 through 2, United States Postal
Service and United States Postal Inspection
Service officials in their individual capacities,

Judge: Hon. William H. Orrick

Defendants.

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Plaintiffs, Defendant United States, and the appearing individual Defendants respectfully
stipulate to and request under Local Rule 6-2 that the Court reset the hearing date for Defendants’
pending motions to dismiss Plaintiffs’ Second Amended Complaint, from July 12 to June 21. This
is the first request for a modification of time regarding the pending motions.
Defendants initially planned to notice the motions hearing for June 21, but Plaintiffs
Stipulated Request to Reset Hearing Date of Pending Motions to Dismiss
Case No. 3:22-cv-03195-WHO

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Case 3:22-cv-03195-WHO Document 68 Filed 05/22/23 Page 2 of 2

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requested that they notice it for June 28 because of a scheduling conflict. On May 17, Defendants

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did so. On May 18, the Court reset the date from June 28 to July 12. But Plaintiffs’ counsel will be

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out of the country for a previously planned vacation on July 12. And Plaintiffs’ counsel’s conflict

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with June 21 has since been resolved. Accordingly, Plaintiffs and Defendants respectfully stipulate

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to and request that the hearing be reset to June 21.

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We note that, accounting for the parties’ and the Court’s availability, if June 21 is no longer

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available, it appears the next opportunity for the hearing will not be until October 11. This is based

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on the Court’s posted availability, Plaintiffs’ counsel’s July travel, and Defendants’ counsel’s July

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to October parental leave.

United States District Court
Northern District of California

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This stipulated request is supported by the accompanying declaration by Plaintiffs’ counsel.

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Dated: May 19, 2023

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s/ Jaba Tsitsuashvili
Jaba Tsitsuashvili (CA Bar No. 309012)
Patrick Jaicomo* (MI Bar No. P-75705)
Trace Mitchell* (DC Bar No. 1780794)
INSTITUTE FOR JUSTICE
901 N. Glebe Road, Suite 900
Arlington, VA 22203
Phone: [phone]
Fax: [phone]
[e-mail]

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s/ Michael A. Keough
ISMAIL J. RAMSEY (CABN 189820)
United States Attorney
MICHELLE LO (NYRN 4325163)
Chief, Civil Division
MICHAEL A. KEOUGH (NYRN 5199666)
Assistant United States Attorney
450 Golden Gate Avenue, Box 36055
San Francisco, California 94102-3495
Telephone: [phone]
Fax: [phone]
[e-mail]

*Admitted pro hac vice
Anna M. Barvir (CA Bar No. 268728)
MICHEL & ASSOCIATES, P.C.
180 E. Ocean Blvd., Suite 200
Long Beach, CA 90802
Phone: [phone]
Fax: [phone]
[e-mail]

Counsel for the United States and the
appearing Individual Defendants

Counsel for Plaintiffs
PURSUANT TO STIPULATION, IT IS SO ORDERED.

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May 22
Dated: _______________,
2023

____________________________
Hon. William H. Orrick
United States District Court Judge

Stipulated Request to Reset Hearing Date of Pending Motions to Dismiss
Case No. 3:22-cv-03195-WHO

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