1 3 4 5 6 7 8 9 10 C.D. Michel - S.B.N. 1448 TRUTANICH MICHEL, LLP Port of Los Angeles 407 North Harbor Boulevard San Pedro, California 90731 (310) 548-0410 Stephen P. Haibrook LAW OFFICES OF STEPHEN P. HALBROOK 10560 Main Street., Suite 404 Fairfax, Virginia 0 (703) 35-76 Don B. Kates - BENENSON & KATES S.B.N. 039193 8 North East 9 th Avenue Battleground, Washington 98604 (360) 666-88 DEC 1 i1z ENQ COUNTY RQR COURT 11 Attorneys for Plaintiffs 13 14 15 18 19 IN THE SUPERIOR COURT OF THE STATE OF CALIFORNIA IN AND FOR THE COUNTY OF FRESNO EDWARD W. HUNT, in his official ) CASE NO. 01CECG0318 capacity as District Attorney of Fresno ) County, and in his personal capacity as a ) JOINT STIPULATION AND PLAINTIFFS citizen and taxpayer, et. al., ) MOTION TO: ) Plaintiffs, ) 1) MODIFY BRIEFING SCHEDULE; ) ) EXCEED PAGE LIMITATION; v. ) 3) SET 1:30 P.M. HEARING STATE OF CALIFORNIA, et. al., Defendants. ) FOR DEFENDANTS DEMURRER TO ) FIRST AMENDED COMPLAINT ) Date: January, 03 ) Time: 439-pm.3) 3O Dept.:.9& 7L WHEREAS, the parties believe that the multiple allegations in plaintiffs First Amended Complaint and multiple demurrer arguments may require extended briefing by the parties on defendants Demurrer, plaintiffs wish to avail themselves of additional time to prepare these briefs, and wish to give the Court extra time to review the materials prior to hearing the Demurrer. THEREFORE, PLAINTIFFS MOVE, AND IT IS HEREBY STIPULATED BETWEEN THE PARTIES (by and through plaintiffs attorney of record, C.D. Michel, and defendants attorney of record, Douglas J. Woods of the California Attorney General s Office) as 1 Stipulation to Modify Filing Schedule
1 follows, subject to the Court s approval: 1. The Demurrer will be filed and served via overnight mail on or before Friday, 3 December 6, 0. The memorandum in support of the Demurrer shall not exceed pages. 4. Any Opposition to defendants Demurrer will be filed and served via overnight mail on 5 or before Monday, January 9, 03. It shall not exceed pages. 6 3. Any Reply to the Opposition to Demurrer will be filed and served via overnight mail on 7 or before Thursday, January, 03 and shall not exceed 15 pages. 8 4. The hearing date for this motion is currently reserved with the court for Thursday, 9 January, 03 at& a.m. in Department 98 of the above referenced court. For the traveling k 10 convenience of the parties, the matter will be heard at 1.3O-p.m. 11 IT IS SO STIPULATED. Date: I I (i /oz_ TRUTANICH MICHEL, LLP: 15 18 Date: Attorneys for Plaintiffs OFFICE OF THE ATTORNEY GENERAL 19 Douglas J. Woods IT IS SO ORDERED. Attorneys for Defendants Date: jj/o 3 c STEPHEN J. NE HON. TUDGE STEPHEN J. KANE Stipulation to Modify Filing Schedule
/03/Q0 14:50 FAX 9 3 4483 Att Gen Offlce lsth Fir 1003 MOY. t3q 11:04AM TRIJTAMICH1XCHEL,LLP 310 548-4813 I follows, subject to the Court s approval: 1. The Demurrer will be filed and served via oveiniglat mail on or befo re Friday, 3 December 6, 0. The memorandum in support of the Demurrer shall not exceed pages. 4. Any Opposition to defendants Demurrer will he filed and served via overnight mail on $ or before Monday, January 9, 03. It shall not exceed pages. 6 3. Any Reply to the Opposition to Demurrer will be filed and served via overnight mail on 7 or before Thursday, January, 03 and shall not exceed 15 pages. 8 4. The hearing date for this motion is currently ieerved with the court forthursday, 9 January, 03 ai8 in Depaflmnent9* of the above referenced court. For the traveling 10 convenience of the parties, the matter will be heard at433-m. Ii IT IS SO STIPULATED. Date: TRUT.ANICH MICHEL, LLP: is C. D. Michel Atthrnys for Plaintiffs Date; OFFICE OF THE ATTORNEY GENERAL IT IS SO ORDERED. Attorncy or Def dants Date; HOl. IUDGE STEPHEN J. KA StiDulation th 4rn1f
1 PROOF OF SERVICE STATE OF CAIJFORNL& 3 COUNTY OF LOS ANGELES 4 I, Haydee Villegas, am employed in the City of San Pedro, Los Angeles County, California. I am over the age eighteen (18) years and am not a party to the within action. My 5 business address is 407 North Harbor Boulevard, San Pedro, California 90731. 6 On December 3, 0, I served the foregoing document(s) described as 7 JOINT STIPULATION AND PLAINTIFFS MOTION TO: 1) MODIFY BRIEFING SCHEDULE; ) EXCEED PAGE LIMITATION; 3) SET 1:30 P.M. HEARING 8 FOR DEFENDANT S DEMURRER TO FIRST AMENDED COMPLAINT 9 on the interested parties in this action by placing []the original 10 [X] a true and correct copy 11 thereof enclosed in sealed envelope(s) addressed as follows: Douglas J. Woods Office of the Attorney General 1300 I Street 13 Sacramento, CA 95814 14 (9) 3-5567 (BY MAIL) As follows: I am readily familiar with the firm s practice of collection and 15 processing correspondence for mailing. Under the practice it would be deposited with the U.S. Postal Service on that same day with postage thereon fully prepaid at San Pedro, California, in the ordinary course of business. I am aware that on motion of the party served, service is presumed invalid if postal cancellation date is more than one day after date of deposit for mailing an affidavit. 18 Executed on December 3, 0, at San Pedro, California. 19 (PERSONAL SERVICE) I caused such envelope to delivered by hand to the offices of the addressee. Executed on December 3, 0, at San Pedro, California. (STATE) I declare under penalty of perjury under the laws of the State of California that the foregoing is true and correct. (FEDERAL) I declare that I am employed in the office of this court at whose direction the service was made. 3 Stipulation to Modify Filing Schedule
1 C.D.Michel-S.B.N.1448 U TRUTANICH MICHEL, LLP Port of Los Angeles 407 North Harbor Boulevard 3 San Pedro, California 90731 4 (310)548-0410 Stephen P. Haibrook 5 LAW OFFICES OF STEPHEN P. HALBROOK 10560 Main Street., Suite 404 6 Fairfax, Virginia 0 7 10 (703) 35-76 Don B. Kates - S.B.N. 039193 8 BENF,NSON&KATES 8 North East 9 th Avenue 9 Battleground, Washington 98604 (360) 666-88 11 Attorneys for Plaintiffs 13 14 IN THE SUPERIOR COURT OF THE STATE OF CALIFORNIA IN AN]) FOR THE COUNTY OF FRESNO EDWARD W. HUNT, in his official ) CASE NO. O1CECGO3 18 15 capacity as District Attorney of Fresno ) County, and in his personal capacity as a ) JOINT STIPULATION AND PLAINTIFFS citizen and taxpayer, et. al., ) MOTION TO: Plaintiffs, ) 1) MODIFY BRIEFING SCHEDULE; ) ) ) EXCEED PAGE LIMITATION; 18 v. ) 3) SET 1:30 P.M. HEARING ) FOR DEFENDANTS DEMURRER TO 19 STATE OF CALIFORNIA, et. al., ) FIRST AMENDED COMPLAINT Defendants. ) Date: January, 03 ) ) Time: -1O p.m. Dept.: 48k- WHEREAS, the parties believe that the multiple allegations in plaintiffs First Amended Complaint and multiple demurrer arguments may require extended briefing by the parties on defendants Demurrer, plaintiffs wish to avail themselves of additional time to prepare these briefs, and wish to give the Court extra time to review the materials prior to hearing the Demurrer. THEREFORE, PLAINTIFFS MOVE, AND IT IS HEREBY STIPULATED BETWEEN THE PARTIES (by and through plaintiffs attorney of record, C.D. Michel, and defendants attorney of record, Douglas J. Woods of the California Attorney General s Office) as 1 Stioulation to Mo fvfilincr rhpdii1i
1 follows, subject to the Court s approval: 1. The Demurrer will be filed and served via overnight mail on or before Friday, 3 December 6, 0. The memorandum in support of the Demurrer shall not exceed pages. 4. Any Opposition to defendants Demurrer will be filed and served via overnight mail on 5 or before Monday, January 9, 03. It shall not exceed pages. 6 3. Any Reply to the Opposition to Demurrer will be filed and served via overnight mail on 7 or before Thursday, January, 03 and shall not exceed 15 pages. 8 4. The hearing date for this motion is currently reserved with the court for Thursday, 9 January, 03 at g44j4m. in Department of the above referenced court. For the traveling 10 convenience of the parties, the matter will be heard at :1E) p.m. 11 IT IS SO STIPULATED. Date: I I (i/- TRUTANICH MICHEL, LLP: 18 Date: Attorneys for Plaintiffs OFFICE OF THE ATTORNEY GENERAL 19 Douglas J. Woods Attorneys for Defendants IT IS SO ORDERED. Date: /A/ô Stipulation to Modify Filing Schedule STEPHEN J, KANE HON. JUDGE STEPHEN J. KAI E
13/03/Q0 14:50 FAX 918 3 4483 Att Gen Offlce-l6th Fir ooa MOV Q 11:04AM TJTAMICH-MXCHEL,LLP 310-S48-4B13 p.3 1 follows, subject to the Court s approval: 1. The Demurrer will, be filed and served via overnight mail on or before Friday, 3 December 6, 0. The memorandum in support of the Demurrer shall not exceed pages. 4. Any Opposition to defendants Demurrer will li,c filed and served via overnigituiall on 5 or before Monday, January 9, 03. it shall not exceed i pages. 6 3. Any Reply to the Opposition to Demurrer will be filed and served via overnight mail on 7 or before Thursday, January, 03 and shall not exceed 15 pages. 8 4. The hearing date for this motion, is currently re erved with the court forthursday, :) ic 9 January, 03 a 3G thtn. in Departrnent4-A of the above referenced court. For the traveling 10 conveniencie of the parties, the matter will be heard at4-.m. 11 IT IS SO STIPULATED. 1O TRUT.ANICB MICHEL, LLP: Date: t L/C / is C. U. Michel AtIornys for Plaintiffs Date: OFFICE OF THE ATTORNEY GENERAL IT IS SO ORDERED. Attomy ox Def dants Date; HOll. D3E SThPHEN 3. KANE a,... A.. 1 r.. -
1 PROOF OF SERVICE STATE OF CALIFORNIA 3 COUNTY OF LOS ANGELES 4 I, Haydee Villegas, am employed in the City of San Pedro, Los Angeles County, California. I am over the age eighteen (18) years and am not a party to the within action. My 5 business address is 407 North Harbor Boulevard, San Pedro, California 90731. 6 On December 3, 0, I served the foregoing document(s) described as 7 JOINT STIPULATION AND PLAINTIFFS MOTION TO: 1) MODIFY BRIEFING SCHEDULE; ) EXCEED PAGE LIMITATION; 3) SET 1:30 P.M. HEARING 8 FOR DEFENDANT S DEMURRER TO FIRST AMENDED COMPLAINT 9 on the interested parties in this action by placing []the original 10 [X] a true and correct copy thereof enclosed in sealed envelope(s) addressed as follows: 11 Douglas J. Woods Office of the Attorney General 1300 I Street 13 Sacramento, CA 95814 (9) 3-5567 14 X (BY MAIL) As follows: I am readily familiar with the firm s practice of collection and 15 processing correspondence for mailing. Under the practice it would be deposited with the U.S. Postal Service on that same day with postage thereon fully prepaid at San Pedro, California, in the ordinary course of business. I am aware that on motion of the party served, service is presumed invalid if postal cancellation date is more than one day after date of deposit for mailing an affidavit. 18 Executed on December 3, 0, at San Pedro, California. 19 (PERSONAL SERVICE) I caused such envelope to delivered by hand to the offices of the addressee. Executed on December 3, 0, at San Pedro, California.. (STATE) I declare under penalty of perjury under the laws of the State of California that the foregoing is true and correct. (FEDERAL) I declare that I am employed in the office of this court at whose direction the service was made. 3 Stimu1tinn fri MncfifvFilincr Sr}iMii1