Case 2:12-cv-02497-KJM-EFB Document 22 Filed 10/19/12 Page 1 of 3 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 PICKUP, ET AL.

, 2:12-cv-02497 Plaintiff, STIPULATION AND [PROPOSED] ORDER RE: (1) BRIEFING AND HEARING SCHEDULE ON PLAINTIFFS’ MOTION FOR A PRELIMINARY INJUNCTION; (2) PAGE LIMITS FOR BRIEFING ON PLAINTIFFS’ MOTION; AND (3) Defendant. CALIFORNIA STATE DEFENDANTS’ TIME TO ANSWER OR OTHERWISE RESPOND TO PLAINTIFFS’ COMPLAINT Date: Time: Courtroom: Judge: KAMALA D. HARRIS, State Bar No. 146672 Attorney General of California TAMAR PACHTER, State Bar No. 146083 Supervising Deputy Attorney General PAUL STEIN, State Bar No. 184956 Deputy Attorney General 455 Golden Gate Avenue, Suite 11000 San Francisco, CA 94102-7004 Telephone: (415) 703-5740 Fax: (415) 703-1234 E-mail: Paul.Stein@doj.ca.gov Attorneys for California State Defendants IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF CALIFORNIA SACRAMENTO DIVISION

v. BROWN, ET AL.,

3, 15th Floor The Honorable Kimberly J. Mueller Trial Date: None set Action Filed: October 4, 2012 Plaintiffs David Pickup et al. (Plaintiffs) and Defendants Edmund G. Brown, Jr., Governor of the State of California in his official capacity; Anna M. Caballero, Secretary of the California State and Consumer Services Agency, in her official capacity; Kim Madsen, Executive Officer of the California Board of Behavioral Sciences, in her official capacity; Michael Erickson, President of the California Board of Psychology, in his official capacity; and Sharon Levine, President of 1
Stipulation re Plaintiffs’ MPI; Page Limits; Defendants’ Time To Respond (2:12-cv-02497)

Case 2:12-cv-02497-KJM-EFB Document 22 Filed 10/19/12 Page 2 of 3 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 the Medical Board of California, in his official capacity (collectively, the California State Defendants), by and through their respective counsel, hereby stipulate and agree as follows: (1) On October 15, 2012, Plaintiffs served the summons and complaint in this action, as well as separate motions for a preliminary injunction and to proceed using pseudonyms, on the California State Defendants; (2) Plaintiffs noticed hearings on their motions for November 9, 2012, less than twenty-eight (28) days from the date of service, and submitted a brief in excess of twenty (20) pages in support of their motion for a preliminary injunction; Plaintiffs subsequently filed a motion seeking leave to exceed the page limit, which motion has not been decided; and (3) On October 18, 2012, the parties met and conferred and reached agreement regarding the briefing and hearing schedule on Plaintiffs’ motions for a preliminary injunction and to proceed using pseudonyms; Plaintiffs’ overlong brief in support of its motion for a preliminary injunction; and the California State Defendants’ deadline to answer or otherwise respond to the complaint in this action, which is presently November 5, 2012. Now, based on the foregoing, and in the interests of conserving party and judicial resources, and the orderly and efficient administration of this case, the parties further stipulate and agree that: (A) The hearing on Plaintiffs’ motions for a preliminary injunction and to proceed using pseudonyms shall be held on Friday, November 30, 2012, at 10:00 a.m. in the abovereferenced courtroom; (B) Plaintiffs’ overlong memorandum of points and authorities in support of their motion for a preliminary injunction, filed on October 4, 2012, and Plaintiffs’ motion for leave to file an overlong brief, filed on October 11, 2012, are hereby withdrawn; (C) Plaintiffs shall re-file and serve their memorandum of points and authorities in support of their motion for a preliminary injunction, which shall not exceed thirty (30) pages, no later than Monday, October 22, 2012; (D) The California State Defendants shall file and serve their opposition to the motion for a preliminary injunction, which shall not exceed thirty (30) pages, and their opposition, if any, to Plaintiffs’ motion to proceed using pseudonyms, no later than Friday, November 9, 2012; (E) Plaintiffs shall file and serve their reply in support of their motion for a preliminary injunction, if any, which shall not exceed fifteen (15) pages, no later than Friday, November, 16, 2012; and 2
Stipulation re Plaintiffs’ MPI; Page Limits; Defendants’ Time To Respond (2:12-cv-02497)

Case 2:12-cv-02497-KJM-EFB Document 22 Filed 10/19/12 Page 3 of 3 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 3
Stipulation re Plaintiffs’ MPI; Page Limits; Defendants’ Time To Respond (2:12-cv-02497) SA2012108115 20645070.doc

(F)

The California State Defendants shall answer or otherwise respond to the

complaint in this action no later than twenty-one (21) days after this Court issues its ruling on Plaintiffs’ motion for a preliminary injunction. Dated: October 19, 2012 Respectfully submitted, KAMALA D. HARRIS Attorney General of California TAMAR PACHTER Supervising Deputy Attorney General

/s/ Paul Stein PAUL STEIN Deputy Attorney General Attorneys for California State Defendants LIBERTY COUNSEL P.O. BOX 11108 Lynchburg, VA 24506 Tel: (434) 592-7000 Fax: (434) 592-7700 Email: court@lc.org /s/ Mary E. McAlister MARY E. MCALISTER (SBN148570) Attorneys for Plaintiffs David Pickup et al.

HAVING CONSIDERED THE STIPULATION OF THE PARTIES, AND GOOD CAUSE APPEARING, IT IS SO ORDERED:

Dated: _____________________

___________________________ Hon. Kimberly J. Mueller

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