Utah Coalition of La Raza et al v. Herbert et al

Filing 42

NOTICE of Hearing by Centro Civico Mexicano, Alicia Cervantes, Coalition of Utah Progressives, Eliana Larios, Latin American Chamber of Commerce, Milton Ivan Salazar-Gomez, Salt Lake City Brown Berets, Service Employees International Union, Utah Coalition of La Raza, Workers United Rocky Mountain Joint Board (Goddard, Darcy)

Linton Joaquin*
Karen C. Tumlin*
Shiu-Ming Cheer*
Melissa S. Keaney*
NATIONAL IMMIGRATION LAW
CENTER
3435 Wilshire Boulevard, Suite 2850
Los Angeles, California 90010
Telephone: [phone]
Facsimile: [phone]
[e-mail]
[e-mail]
[e-mail]
[e-mail]
Omar C. Jadwat*
Andre I. Segura*
Elora Mukherjee*
AMERICAN CIVIL LIBERTIES UNION
FOUNDATION
125 Broad Street, 18th Floor
New York, New York 10004
Telephone: [phone]
Facsimile: [phone]
[e-mail]
[e-mail]
[e-mail]
Attorneys for Plaintiffs
* Admitted pro hac vice
+ Counsel for all plaintiffs except SEIU and
Workers’ United

Cecillia D. Wang*
Katherine Desormeau*
AMERICAN CIVIL LIBERTIES
UNION FOUNDATION IMMIGRANTS’
RIGHTS PROJECT
39 Drumm Street
San Francisco, California 94111
Telephone: [phone]
Facsimile: [phone]
[e-mail]
[e-mail]
Darcy M. Goddard (USB No. 13426)
Esperanza Granados (USB No. 11894)
AMERICAN CIVIL LIBERTIES
UNION OF UTAH FOUNDATION, INC.
355 North 300 West
Salt Lake City, Utah 84103
Telephone: [phone]
Facsimile: [phone]
[e-mail]
[e-mail]
Bradley S. Phillips*+
MUNGER, TOLLES & OLSON LLP
355 South Grand Avenue
Thirty-Fifth Floor
Los Angeles, CA 90071-1560
Telephone:
[phone]
Facsimile:
[phone]
[e-mail]

UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF UTAH
CENTRAL DIVISION
Utah Coalition of La Raza, et al.,
Plaintiffs,
v.

NOTICE OF HEARING
Case No. 2:11-cv-00401-CW

Gary R. Herbert, et al.,
Defendants.

Judge: Clark Waddoups

Plaintiffs, by and through counsel, serve notice that the Court has scheduled a hearing on
Plaintiffs’ Motion for Preliminary Injunction (Docket No. 36) for May 10, 2011, at 2:00 p.m. at
the United States District Court for the District of Utah, in room 102, before the Honorable Clark
Waddoups (“May 10 hearing”). The Court has indicated that counsel should be prepared to
discuss the status of the case and the proposed briefing schedule on Plaintiffs’ Motion for
Preliminary Injunction.
Plaintiffs further serve notice that, if the parties are unable to negotiate and stipulate to a
stay of enforcement of the challenged statute (Utah HB 497) pending decision by the Court on
Plaintiffs’ Motion for Preliminary Injunction, Plaintiffs will be seeking at the May 10 hearing an
order of the Court enjoining enforcement of the statute in order to preserve the status quo.
Counsel for Plaintiffs, Darcy M. Goddard, has discussed such a proposed agreement and
stipulation with counsel for Defendants, Assistant Attorney General Thom D. Roberts, on several
occasions since counsel for Defendants entered their appearances on May 5, 2011. Counsel have
been unable to reach agreement. Ms. Goddard advised Mr. Roberts by telephone at
approximately 3:00 p.m. yesterday, May 9, 2011, that Plaintiffs would seek an order from the
Court enjoining enforcement of HB 497, and thereby preserving the status quo, if counsel were
unable to reach an agreement and stipulation prior to the May 10 hearing.
This notice will be filed through the Court’s CM/ECF e-filing system, which will
automatically send notice to counsel for Defendants. Plaintiffs’ counsel will simultaneously
send courtesy copies of this notice by e-mail to Defendants’ counsel Mr. Roberts and his cocounsel Assistant Attorney General Jerrold Jensen.

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Dated this 10th day of May, 2011.

Respectfully submitted,
/s/ Darcy M. Goddard
AMERICAN CIVIL LIBERTIES UNION
OF UTAH FOUNDATION, INC.
/s/ Cecillia D. Wang
AMERICAN CIVIL LIBERTIES UNION
FOUNDATION
IMMIGRANTS’ RIGHTS PROJECT
/s/ Linton Joaquin
NATIONAL IMMIGRATION LAW CENTER
/s/ Elora Mukherjee
AMERICAN
CIVIL
LIBERTIES
FOUNDATION
RACIAL JUSTICE PROGRAM
/s/ Bradley S. Phillips
MUNGER, TOLLES & OLSON LLP

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UNION

CERTIFICATE OF SERVICE
I, Darcy M. Goddard, hereby certify that on May 10, 2011, at approximately 11:20 a.m., I
electronically filed this Notice of Hearing through the Court’s CM/ECF electronic filing system,
which will automatically send notification to:
JERROLD S. JENSEN (#1678)
THOM D. ROBERTS (#2773)
Assistant Attorneys General
MARK L. SHURTLEFF (#4666)
Attorney General
160 East 300 South, 5th Floor
P.O. Box 140857
Salt Lake City, Utah 84114-0857
Telephone: [phone]
[e-mail]
[e-mail]
Attorneys For State Defendants
Dated this 10th day of May, 2011.
s/ Darcy M. Goddard
Darcy M. Goddard

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