IN THE UNITED STATES DISTRICT COURT FOR THE CENTRAL DISTRICT OF CALIFORNIA RIVERSIDE DIVISION. Plaintiffs,

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1 Case :-cv-0-jgb-kk Document Filed /0/ Page of Page ID #: 0 0 XAVIER BECERRA Attorney General of California MARK R. BECKINGTON Supervising GABRIELLE D. BOUTIN ENRIQUE A. MONAGAS State Bar No South Spring Street, Suite 0 Los Angeles, CA 00 Telephone: () -0 Fax: () - Enrique.Monagas@doj.ca.gov Attorneys for the State of California IN THE UNITED STATES DISTRICT COURT FOR THE CENTRAL DISTRICT OF CALIFORNIA AIDEN STOCKMAN, et al., v. RIVERSIDE DIVISION Plaintiffs, DONALD J. TRUMP, in his official capacity as President of the United States, et al., Defendants. :-CV-0-JGB-KK STATE OF CALIFORNIA S NOTICE OF MOTION AND ; [PROPOSED] ORDER Date: November 0, 0 Time: :00 a.m. Courtroom: Judge: Hon. Jesus G. Bernal (:-CV-0-JGB-KK)

2 Case :-cv-0-jgb-kk Document Filed /0/ Page of Page ID #: 0 0 NOTICE OF TO THE COURT, ALL PARTIES, THEIR COUNSEL OF RECORD, AND THE CLERK OF THE COURT: PLEASE TAKE NOTICE that Proposed-Intervenor the State of California hereby moves this Court pursuant to L.R. - for an order shortening time for notice on its Motion to Intervene (Dkt. No. ), so that it may be heard November 0, 0, concurrently with Plaintiffs Motion for Preliminary Injunction. Dkt. No.. The State of California further hereby moves the Court to establish a briefing schedule for opposition and reply papers on the Motion to Intervene. Good cause exists to grant this application and hear the Motion to Intervene on shortened notice in that there is insufficient time for the State s Motion to Intervene to be heard on regular notice in advance of the hearing on the Motion for Preliminary Injunction. The State s participation in the oral argument at the hearing is vital to protect the State s important interests identified in the Motion to Intervene. This motion is based on this Notice of Motion and Motion; the Motion to Intervene; the Declaration of Enrique A. Monagas and attached exhibits; all pleadings and papers filed herein; oral argument of counsel; and any other materials and information that may be presented to the Court at the hearing. ARGUMENT The State of California today filed a Motion to Intervene as party plaintiffs. Dkt. No.. As is set forth in its motion, the State is seeking to intervene at the onset of this litigation to protect its interests, including: preventing invidious discrimination harmful to the State s National Guard; avoiding harm to California s veterans, active service members, and those who wish to serve; safeguarding the State s public institutions of higher education from discrimination in their ROTC programs; and protecting the State s transgender community more broadly. Thus, (:-CV-0-JGB-KK)

3 Case :-cv-0-jgb-kk Document Filed /0/ Page of Page ID #: 0 0 California would be prejudiced if it were unable to advance its interests at the oral argument in support of Plaintiffs Motion for Preliminary Injunction, calendared for November 0, 0. California filed its Motion to Intervene as soon as reasonably practicable. Given the -day notice period for civil motions required by L.R. -, however, California s Motion to Intervene could not be heard in time for it to participate at the preliminary injunction hearing. Under L.R. -, this Court may order a shorter time for notice. Plaintiffs have informed California that they support its Motion to Intervene and Motion to Shorten Time, so long as intervention does not alter the currently scheduled November 0, 0 hearing on Plaintiffs Motion for a Preliminary Injunction. Monagas Decl.,. Defendants have not indicated whether they will oppose California s motions. Monagas Decl.,. However, given that Defendants have already briefed and opposed a similar motion to intervene by the State of Washington in a similar challenge to President Trump s directive to reinstate a ban on military service by transgender individuals, they will not be prejudiced by the motion to shorten time. Karnoski, et al. v. Trump, et al., No. :-cv- (W. Dist. Wash); Monagas Decl., Ex. G (Defendants Opposition to the State of Washington s Motion to Intervene). For the foregoing reasons, California respectfully requests that this Court shorten the time for notice on its Motion to Intervene, so that it may be heard concurrently with the Motion for Preliminary Injunction on November 0, 0. Further, the State asks that the Court set a reasonable briefing schedule for opposition and reply papers on the Motion to Intervene. If the Court determines that shortening time is not appropriate, in the interests of justice and in light of the harm caused by the challenged federal policy, the State respectfully requests that (:-CV-0-JGB-KK)

4 Case :-cv-0-jgb-kk Document Filed /0/ Page of Page ID #: 0 0 the November 0, 0 preliminary injunction hearing remain on calendar and that the Motion to Intervene be heard in regular course. Dated: November, 0 SA00.docx Respectfully submitted, XAVIER BECERRA Attorney General of California MARK R. BECKINGTON Supervising GABRIELLE D. BOUTIN /s/ Enrique A. Monagas ENRIQUE A. MONAGAS Attorneys for the State of California (:-CV-0-JGB-KK)

5 Case :-cv-0-jgb-kk Document - Filed /0/ Page of Page ID #:0 0 0 IN THE UNITED STATES DISTRICT COURT FOR THE CENTRAL DISTRICT OF CALIFORNIA AIDEN STOCKMAN, et al., v. RIVERSIDE DIVISION Plaintiffs, DONALD J. TRUMP, in his official capacity as President of the United States, et al., Defendants. :-CV-0-JGB-KK [PROPOSED] ORDER RE STATE OF CALIFORNIA S Date: November 0, 0 Time: :00 a.m. Courtroom: Judge: Hon. Jesus G. Bernal [PROPOSED] ORDER (:-CV-0-JGB-KK)

6 Case :-cv-0-jgb-kk Document - Filed /0/ Page of Page ID #: 0 0 Good cause appearing, the motion of Proposed Intervenor State of California for shortened time on its Motion to Intervene is hereby GRANTED. Any opposition to the Motion to Intervene shall be filed no later than:. Any reply in support of the Motion to Intervene shall be filed no later than:. A hearing on the Motion to Intervene is set for November 0, 0 at :00 a.m. in Courtroom of the above-entitled Court. Dated: IT IS SO ORDERED. SA00 0.docx The Honorable Jesus G. Bernal [PROPOSED] ORDER (:-CV-0-JGB-KK)

Case 3:18-cv RS Document 30 Filed 06/18/18 Page 1 of 6

Case 3:18-cv RS Document 30 Filed 06/18/18 Page 1 of 6 Case :-cv-0-rs Document 0 Filed 0// Page of CHAD A. READLER Acting Assistant Attorney General CARLOTTA P. WELLS Assistant Director KATE BAILEY STEPHEN EHRLICH CAROL FEDERIGHI Trial Attorneys United States