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Mark Aaron Haynie, Brendan v. Kamala Harris

IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF CALIFORNIA


July 24, 2012

MARK AARON HAYNIE, BRENDAN JOHN RICHARDS, THE CALGUNS
FOUNDATION, INC., AND THE SECOND AMENDMENT FOUNDATION, INC., PLAINTIFFS,
v.
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 SECOND AMENDMENT FOUNDATION, INC. ,
PLAINTIFFS,
v.
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. MAX JOSEPH PLOG-HOROWITZ, THE CALGUNS FOUNDATION, INC., AND THE SECOND AMENDMENT FOUNDATION, INC., PLAINTIFFS,
v.
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.

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

attorneys of record that the pending Case Management Conference currently set for July 27, 2012 12 in Courtroom 10, 19th Floor of the U.S. District Court for the Northern District of California 13 should be reset. 14 a motion to dismiss under submission that has been fully briefed and was argued on May 4, 2012. 16

The parties believe that it would be a more productive use of the Court's time and resources to 17 have the Case Management Conference after a ruling on the motion to dismiss has been issued 18

19 some date after the Court anticipates releasing its order from the May 4, 2012 hearing. 20 21 unavailable on the following Fridays: August 10 and 17, September 27, and October 5, 2012. 22 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 27 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.) 28

IT IS HEREBY STIPULATED*fn1 by and between the parties hereto through their respective The Defendants in Richards v. Harris I (Rohnert Park), Case No.: 3:11-CV-02493 SI have Accordingly, the parties propose that the Court reset the Case Management Conference to For the convenience of the Court and its staff, Plaintiffs' counsel advises that he is

SO STIPULATED.

Dated: July 19, 2012 Dated: July 19, 2012 3 /s/ Ross Moody /s/ Donald Kilmer 4 Ross Moody Donald Kilmer 5 Counsel for Defendants Counsel for Plaintiffs Harris & California Dept. of Justice 6 7 Dated: July 19, 2012 8 /s/ Robert W. Henkels 9 Robert W. Henkels Counsel for Defendants 10 City of Rohnert Park & Becker Counsel for Defendants 11 Cotati Police Department, City of Cotati, & Lyssand 12 13 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 United States that I have in my possession e-mail correspondence from Donald Kilmer and 18 Robert Henkels that the content of this document is acceptable to all persons required to sign the 19 document. I declare that this document was signed in San Francisco, CA on July 19, 2012. 20 21

/s/ Ross Moody ________________________________ 22 Ross Moody Deputy Attorney General 23 Attorney for Defendants California Department of Justice and Attorney General Kamala D. Harris 25

ORDER

The Case Management Conference in these consolidated and related matters currently set 27 for July 27, 2012 is reset to: (Date) _________________________, at (Time): _____________, 28 in Courtroom 10, 19th Floor of the U.S. District Court for the Northern District of California -- August 24, 2012 3:00 p.m. San Francisco. A Joint Case Management Conference Statement shall be filed seven (7) calendar 2 days before the new date. 3

United States District Judge


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