Case: Comite de Jornaleros de Redondo Beach v. City of Redondo Beach

U.S. Court of Appeals for the Ninth Circuit

U.S. Court of Appeals for the Ninth Circuit

U.S. Court of Appeals for the Ninth Circuit

Supreme Court of the United States

Legal Defense Fund

Scott Cummings

COMPLAINT against defendant Redondo Beach City of. (Filing fee $150.) filed by plaintiffs Comite de Jornaleros de Redondo Beach, National Day Laborer Organizing Network.(jag, ) (Entered: 11/19/2004)

FAX number for Attorney Belinda Anne Escobosa, Thomas A Saenz, Shaheena Ahmad Simons is 213-629-0266. (jag, )

20-Day Summons Issued re Complaint - (Discovery) 1 as to Redondo Beach City of. (jag, )

CERTIFICATION and NOTICE of Interested Parties filed by Plaintiffs Comite de Jornaleros de Redondo Beach, National Day Laborer Organizing Network. (jag, ) (Entered: 11/19/2004)

STANDING ORDER by Judge Consuelo B. Marshall. Read This Order Carefully. It Controls The Procedures Used In This Case.(bg, ) (Entered: 11/23/2004)

PROOF OF SERVICE Executed by plaintiff Comite de Jornaleros de Redondo Beach, National Day Laborer Organizing Network, upon Redondo Beach City of served on 11/17/2004, answer due 12/7/2004. The Summons and Complaint were served by personal service, by FRCP statute, upon Jerold A Goddard, City Attorney. Due Dilligence declaration not attached. Original Summons not returned. (bg, ) (Entered: 11/23/2004)

EX PARTE APPLICATION for Temporary Restraining Order and Order to Show Cause re Preliminary Injunction filed by Plaintiffs Comite de Jornaleros de Redondo Beach, National Day Laborer Organizing Network. Lodged proposed order. (shb, ) (Entered: 11/23/2004)

MEMORANDUM of points and authorities in Support of EX PARTE APPLICATION for Temporary Restraining Order and Order to Show Cause re Preliminary Injunction 7 filed by Plaintiffs Comite de Jornaleros de Redondo Beach, National Day Laborer Organizing Network. (shb, ) (Entered: 11/23/2004)

DECLARATION of Shaheena Ahmad Simons in support of EX PARTE APPLICATION for Temporary Restraining Order and Order to Show Cause re Preliminary Injunction 7 filed by Plaintiffs Comite de Jornaleros de Redondo Beach, National Day Laborer Organizing Network. (shb, ) (Entered: 11/23/2004)

DECLARATION of Chris Newman in support of EX PARTE APPLICATION for Temporary Restraining Order and Order to Show Cause re Preliminary Injunction 7 filed by Plaintiffs Comite de Jornaleros de Redondo Beach, National Day Laborer Organizing Network. (shb, ) (Entered: 11/23/2004)

NOTICE of Interested Parties filed by Defendant Redondo Beach City of. (mch, ) (Entered: 11/22/2004)

FAX number for Attorney Jerold A Goddard is 310-372-3886. (mch, )

NOTICE of Related Case(s) filed by Defendant Redondo Beach City of. Related Case(s): CV 04-3521 SJO (Ex) (rn, ) (Entered: 11/23/2004)

OPPOSITION TO DEFENDANTS Notice of Related Case(s) 6 filed by Plaintiffs Comite de Jornaleros de Redondo Beach, National Day Laborer Organizing Network. (mch, ) (Entered: 11/24/2004)

MINUTES OF In Chambers Conference held before Judge Consuelo B. Marshall: On 11/18/04, Plaintiffs filed an Ex Parte Application for a Temporary Restraining Order and Order to Show Cause regarding Preliminary Injunciton. Upon consideration of the papers submitted, the Court requests supplemental briefing from Plaintiffs on the issue of whether the Redondo Beach Ordinance at issue in this case is content-neutral. Specifically, the Court requests that Plaintiffs distinguish the cases of United States v Kokinda and ACORN v City of Phoenix. Plaintiffs shall file their supplemental brief no later than 11/23/04 (cc: plaintiff/defendant (or parties))Court Reporter: not applicable. (rl, ) (Entered: 11/24/2004)

JOINT STIPULATION of the Parties regarding Plaintiff's Application for a Temporary Restraining Order and for a Briefing Schedule and [proposed] Order filed by Defendants Redondo Beach City of. (cc:plaintiff/defenant (or parties)) (See document for further details) (rl, ) (Entered: 11/24/2004)

ORDER by Judge Consuelo B. Marshall: IT IS SO ORDERED that this Joint Stipulation does not preclude the City of Redondo Beach from enforcing any other laws and/or Ordinances currently in effect, with the exception of Redondo Beach Municipal Code section 3-7.1601. The hearing regarind Plaintiffs' 7 EX PARTE APPLICATION for Temporary Restraining Order will be placed on calendar on 12/6/04 at 8:00pm or as soon thereafter as the Court may decide. Defendants will file and serve their objections to the Application for Temporary Restraining Order by 11/26/04 at 5:00pm and Plaintiffs wil file and serve their reply by 12/2/04 at 3:00pm. Service by mail and fax is acceptable by all parties (cc: plaintiff/defendant (or parties)) (rl, ) (Entered: 11/24/2004)

SUPPLEMENTAL BRIEF re content-neutrality, filed by Plaintiffs (mg, ) (Entered: 11/30/2004)

OPPOSITION to EX PARTE APPLICATION for Temporary Restraining Order 7 filed by Defendant Redondo Beach City of. (rl, ) (Entered: 12/07/2004)

REPLY Brief in support of application for a temporary restraining order and order to show cause re preliminary injunction, 13 filed by plaintiffs' Comite de Jornaleros de Redondo Beach, National Day Laborer Organizing Network. (bp, ) (Entered: 12/06/2004)

ORDER by Judge Consuelo B. Marshall granting EX PARTE APPLICATION for TEMPORARY RESTRAINING ORDER and Order to Show Cause re 7 PRELIMINARY INJUNCTION. Defendant City of Redondo Beach is Ordered to Show Cause on 12/13/2004 at 09:00 AM as to why it should not be restrained and enjoined pending trial of this action from undertaking any steps to enforce Section 3-7.1601 of the Redondo Beach Municipal Code. Any briefs in response to this Order to Show Cause shall be filed and served by overnight delivery on opposing counsel no later than 12/9/04 at 12:00 pm. Furthermore, pending hearing on Order to Show Cause, defendant City of Redondo Beach is restrained and enjoined. See document for further details. (mg, ) (Entered: 12/07/2004)

MINUTES by Judge Consuelo B. Marshall: Proceedings: Hearing on plaintiffs Motion for Temporary Restraining Order and/or preliminary injunction 7 . Court takes above motion under submission. Court Reporter: Leandra Amber. (mg, ) (Entered: 12/13/2004)

PREPARED ORDER RE TRANSFER Pursuant to General Order 224 (Related Case) by Clerk; related to CV 04-3531 SJO (Ex). (rn, )

CERTIFICATION of Interested Parties filed by Defendant Redondo Beach City of. (mg, ) (Entered: 12/08/2004)

ANSWER to Complaint - (Discovery) 1 with Jury Demand filed by defendant Redondo Beach City of.(mg, ) (Entered: 12/08/2004)

RECEIPT OF REPORTERS TRANSCRIPT of proceedings for the following dates: 12/6/04 Court Reporter: Leandra Amber. (ghap, ) (Entered: 12/10/2004)

TRANSCRIPT filed for proceedings held on 12/6/04. Court Reporter: Leandra Amber. (ghap, ) (Entered: 12/10/2004)

BRIEF IN SUPPORT of Order to Show Cause Regarding Preliminary Injunction filed by Plaintiff Comite de Jornaleros de Redondo Beach, National Day Laborer Organizing Network. 17 . (yl, ) (Entered: 12/14/2004)

RESPONSE TO ORDER TO SHOW CAUSE Regarding Preliminary Injunction filed by Defendant Redondo Beach City ofto 17 (yl, ) (Entered: 12/28/2004)

OBJECTIONS to plaintiffs proposed findings of fact and conclusions of law filed by Defendant Redondo Beach City of. Lodged proposed P/I (mg, ) (Entered: 12/15/2004)

MINUTES held before Judge Consuelo B. Marshall: Proceedings: Further hearing on plaintiffs Motion for preliminary injunction. Granting EX PARTE APPLICATION for preliminary injunction 7 . Court Reporter: Leandra Amber. (mg, ) (Entered: 12/20/2004)

OBJECTIONS to Plaintiff's Proposed Preliminary Injunction 13 filed by Defendant Redondo Beach City of. (yl, ) (Entered: 12/16/2004)

FINDINGS OF FACT AND CONCLUSIONS OF LAW signed by Consuelo B. Marshall.(mg, ) (Entered: 12/15/2004)

PRELIMINARY INJUNCTION by Judge Consuelo B. Marshall (mg, ) (Entered: 12/15/2004)

RECEIPT OF REPORTERS TRANSCRIPT of proceedings for the following dates: 12/13/04 Court Reporter: Leandra Amber. (cbr, ) (Entered: 12/17/2004)

TRANSCRIPT filed for proceedings held on 12/13/04. Court Reporter: Leandra Amber. (cbr, ) (Entered: 12/17/2004)

ORDER by Judge S. James Otero: IT IS SO ORDERED I decline the transfer of the Redondo Beach Action to my calendar. (see document for further details)(rl, ) (Entered: 12/29/2004)

ORDER RE TRANSFER PURSUANT TO GENERAL ORDER 224 (Related Case) filed. Transfer of case declined by Judge S. James Otero, for the reasons set forth on this order. Related Case No. CV 04-3521 SJO (Ex)(rn, ) (Entered: 12/30/2004)

NOTICE OF PRELIMINARY INJUNCTION APPEAL to 9th CCA filed by defendant Redondo Beach City of. Appeal of Preliminary Injunction Order 26 Filed On: 12/15/04; Entered On: 12/15/04. Filing fee $ 255. Billed. cc: David J. Wilson, Manning and Marder Kass, Ellrod, Ramirez LLP; Jerold Goddard; Thomas A. Saenz. (cbr, ) (Entered: 01/18/2005)

Transmission of Notice of Appeal and Docket Sheet to US Court of Appeals re: Appeal to Circuit Court, 35 . (cbr, )

APPEAL FEE PAID: re Appeal to Circuit Court, 35 as to Defendant Redondo Beach City of; Receipt Number: 20097 in the amount of $255. (cbr, )

ORDER from 9th CCA filed as to Appeal to Circuit Court, 35 filed by Redondo Beach City of, CCA # 05-55094. Order received in this district on 1/26/05. The appeal filed 1/18/05 is a preliminary injunction appeal. Accordingly, Ninth Circuit Rule 3-3 shall apply. The briefing schedule is set. (ghap, ) (Entered: 01/28/2005)

MINUTES by Judge Consuelo B. Marshall: On the Courts own motion, this case is set for a Scheduling Conference on 5/2/2005 at 11:00 AM pursuant to FRCP 16(b). Counsel are reminded of their obligations to dislcose information and confer on a discovery plan not later than 21 days prior to the Scheduling Conference. Counsel shall file a Rule 26(f) discovery plan within 14 days after the conference. Court Reporter: n/a. (mg, ) (Entered: 01/31/2005)

JOINT REPORT OF MEETING OF COUNSEL under FRCP 26(f); estimated length of trial is 2 to 3 days. (mg, ) (Entered: 04/25/2005)

MINUTES OF Scheduling Conference held before Judge Consuelo B. Marshall: Fact Discovery cut-off: 8/30/2005. Expert Discovery cut-off: 9/30/05. Motions shall be set for oral argument on or before 11/7/05 at 11:00 AM. Pretrial Conference set for 1/9/2006 at 03:00 PM. Jury Trial set for 2/21/2006 at 10:00 AM before Honorable Consuelo B. Marshall.Court Reporter: Leandra Amber. (mg, ) (Entered: 05/31/2005)

ORDER by Judge Consuelo B. Marshall granting the NOTICE AND REQUEST of Settlement Procedure Selection (Sp1) to Appear Before magistrate for settlement proceedings.(mg, ) (Entered: 05/04/2005)

ORDER RE DISCOVERY AND TRIAL SCHEDULE by Judge Consuelo B. Marshall: Case Management Conference was held on 5/2/2005. Court establishes the following dates to govern further proceedings in this action: Non-expert discovery cut-off date shall be 8/30/2005. Expert discovery cut-off dates shall be 9/30/2005. Last day for a motion to be heard in this action is 11/7/2005 at 10:00 AM. Set Hearings:Final Pretrial Conference set for 1/9/2006 03:00 PM before Honorable Consuelo B. Marshall. Bench Trial set for 2/21/2006 10:00 AM before Honorable Consuelo B. Marshall. (gk, ) (Entered: 05/23/2005)

MANDATE of 9th CCA filed as to Appeal to Circuit Court, 35, CCA # 05-55094. The judgment of District Court in this cause be, and hereby is affirmed. Mandate received in this district on 06/06/05. (cbr, ) (Entered: 06/10/2005)

ORDER from 9th CCA filed as to Appeal to Circuit Court, 35 filed by Redondo Beach City of, CCA # 05-55094. Order received in this district on 7/1/05. In view of the fact that the matter of attorney's fees will not be ripe for final action in the district until it is known whether appellee is still the prevailing party after final judgment, the "Motion for Order Remanding Fees to the District Court," filed by appellee Comite de Jornaleros de Redondo Beach on 6/8/05, is GRANTED. (ghap, ) (Entered: 07/07/2005)

(See notice of clerical error filed 8/3/05) JOINT STIPULATION RE: MOTION for Protective Order filed by plaintiffs. Motion set for hearing on 8/4/2005 at 10:00 AM before Honorable Patrick J Walsh. (mg, ) Modified on 8/3/2005 (mg, ). (Entered: 07/07/2005)

NOTICE OF MOTION for Protective Order 44 filed by plaintiffs (mg, ) (Entered: 07/07/2005)

DECLARATION of Shaheena Ahmad Simons in support of MOTION for Protective Order 44 filed by plaintiffs (mg, ) (Entered: 07/07/2005)

OPPOSITION to plaintiff MOTION for Protective Order 44 filed by defendant Redondo Beach City of. (jp, ) (Entered: 07/29/2005)

SUPPLEMENTAL BRIEF in support of plaintiffs MOTION for Protective Order 44 filed by plaintiffs Comite de Jornaleros de Redondo Beach, National Day Laborer Organizing Network. (jp, ) (Entered: 07/29/2005)

APPLICATION to Strike defendants Opposition to plaintiffs Motion for Protective Order filed by plaintiffs. Lodged proposed order. (mg, ) (Entered: 08/03/2005)

FAX number for Attorney Araceli S Perez is 213-629-0266. (mg, )

PETITION to Withdraw as Counsel filed by plaintiffs Comite de Jornaleros de Redondo Beach, National Day Laborer Organizing Network. Lodged proposed order. (mg, ) (Entered: 08/04/2005)

RESPONSE to plaintiffs APPLICATION to Strike 50 filed by Defendant Redondo Beach City ofto (mg, ) (Entered: 08/04/2005)

AMENDED SUPPLEMENTAL MEMORANDUM in Support of Joint Stipulation re plaintiffs MOTION for Protective Order 44 ; Declaration of Denise M Caprioli; filed by defendant Redondo Beach City of. (mg, ) (Entered: 08/04/2005)

NOTICE OF CLERICAL ERROR: Due to clerical error the Joint Stipulation Re: Plaintiffs MOTION for Protective Order 44, filed 6/30/05, was erroneously set before Judge Marshall, instead of Judge Walsh. Correction has been made. (mg, ) (Entered: 08/03/2005)

ORDER by Judge Consuelo B. Marshall granting APPLICATION for Attorney Thomas A Saenz to Withdraw as Attorney 51 for plaintiffs (mg, ) (Entered: 08/04/2005)

MINUTES OF Discovery Hearing held before Patrick J. Walsh: The Court GRANTS in part and DENIS in part Plaintiffs Motion for a Protective Order. See Order for details. Tape #: 05-42 (1298-2193). (im, ) (Entered: 08/09/2005)

ORDER by Judge Patrick J. Walsh : granting in part and denying in part 44 Motion for Protective Order, denying 50 Application to Strike. See Order. (im, ) (Entered: 08/09/2005)

JOINT STIPULATION re deposition of persons most knowledgeable filed by defendant Redondo Beach City of. (mg, ) (Entered: 08/18/2005)

NOTICE of Change of Attorney Information changing firm address of Mexican American Legal Defense and Educational Fund, to 634 South Spring Street, 11th Floor, Los Angeles, CA 90014 for attorney Araceli S Perez. Filed by plaintiffs Comite de Jornaleros de Redondo Beach, National Day Laborer Organizing Network (mg, ) (Entered: 08/19/2005)

MOTION for Reconsideration of Magistrate Judge's Order granting in part and denying in part Plaintiff's Motion for Protective Order, 56 filed by Plaintiffs Comite de Jornaleros de Redondo Beach, National Day Laborer Organizing Network. Motion set for hearing on 9/12/2005 at 10:00 AM before Honorable Consuelo B. Marshall. (shb, ) (Entered: 08/24/2005)

NOTICE OF MOTION for Reconsideration of Magistrate Judge's Order granting in part and denying in part, Plaintiff's Motion for Protective Order, Order on Application to Strike 56 59 filed by Plaintiffs Comite de Jornaleros de Redondo Beach, National Day Laborer Organizing Network. Motion set for hearing on 9/12/2005 at 10:00 AM before Honorable Consuelo B. Marshall. (shb, ) (Entered: 08/24/2005)

OPPOSITION to MOTION for Reconsideration 56 59 of Magistrate Judges Order granting in part and denying in part plaintiffs Motion for a protective order; Memorandum of points and authorities; Declaration of David J Wilson. Filed by defendant Redondo Beach City of. (mg, ) (Entered: 09/02/2005)

MINUTES (IN CHAMBERS ORDER) by Judge Consuelo B. Marshall: On the Courts own motion, plaintiffs MOTION for Reconsideration of Magistrate Judges order granting in part, denying in part, plaintiffs Motion for Protective Order 56 59 . The motion is continued to 9/19/2005 at 10:00 AM before Honorable Consuelo B. Marshall. Replies, if any shall be filed with the Court on or before 9/2/05. Court Reporter: N/A. (mg, ) (Entered: 08/31/2005)

[CORRECTED] JOINT STIPULATION re: Depositions of persons most knowledgeable from plaintiffs Comite de Jornaleros de Redondo Beach and National day Laborer Organizing Network (mg, ) (Entered: 09/08/2005)

REPLY to defendant Opposition to MOTION for Reconsideration of Magistrate Judges Order granting in part plaintiff Motion for a Protective Order 59 filed by plaintiffs Comite de Jornaleros de Redondo Beach, National Day Laborer Organizing Network. (jp, ) (Entered: 09/13/2005)

MINUTES by Judge Consuelo B. Marshall: Plaintiffs MOTION for Reconsideration 56 59 is granted. Court to issue a formal order. Court Reporter: Leandra Amber. (mg, ) (Entered: 09/30/2005)

ORDER by Judge Consuelo B. Marshall granting plaintiffs Motion for reconsideration of Magistrate Judges Order granting in part and denying in part plaintiffs Motion for a protective order 60 . Based on the foregoing, the Court finds that immigration status is irrelevant to plaintiffs standing to challenge the Ordinance and therefore GRANTS plaintiffs Motion for Reconsideration. Any discovery of plaintiffs members immigrations status for purposes of challenging standing is prohibited. (mg, ) (Entered: 10/06/2005)

NOTICE OF MOTION AND MOTION for Summary Judgment; Memorandum of points and authorities in support; Declarations of Rody A Contreras, Michael Webb and David J Wilson; filed by defendant Redondo Beach City of. Motion set for hearing on 10/31/2005 at 10:00 AM before Honorable Consuelo B. Marshall. Lodged proposed statement and order. (mg, ) (Entered: 10/11/2005)

APPENDIX OF DECLARATIONS in support of defendants MOTION for Summary Judgment and/or Adjudication of Issues 67 filed by defendant Redondo Beach City of. (mg, ) (Entered: 10/11/2005)

APPENDIX OF EXHIBITS (Volume I of III, Exh A-NN) in support of defendants MOTION for Summary Judgment 67 filed by defendant Redondo Beach City of. (mg, ) (Entered: 10/11/2005)

APPENDIX OF EXHIBITS (Vol II of III, Exh OO-RRR) in support of defendants MOTION for Summary Judgment 67 filed by defendant Redondo Beach City of. (mg, ) (Entered: 10/11/2005)

APPENDIX OF EXHIBITS (Vol III of III, Exh SSS-GGG) in support of MOTION for Summary Judgment 67 filed by defendant Redondo Beach City of. (mg, ) (Entered: 10/11/2005)

PROOF OF SERVICE filed by defendant Redondo Beach City of MOTION for Summary Judgment 67 and accompanying documents 68, 69, 70, 71 ; served on 10/7/05. (mg, ) (Entered: 10/11/2005)

JOINT STIPULATION to extend the deadline for hearing on Motion for Summary Judgment filed by plaintiffs. Lodged proposed order. (mg, ) (Entered: 10/17/2005)

ORDER by Judge Consuelo B. Marshall extending the time for hearing motions in this case from 11/7/05 to 11/28/05 at 10:00 AM. Defendants MOTION for Summary Judgment 67 shall be heard on 11/28/2005 at 10:00 AM before Honorable Consuelo B. Marshall. Plaintiffs are permitted to notice their Motion for Summary Judgment for a hearing on 11/28/05 at 10:00 AM. Oppositions, if any are due 10/31/2005. Replies, if any, are due 11/7/2005. (mg, ) (Entered: 10/14/2005)

MOTION for Summary Judgment; Memorandum of points and authorities in support; filed by plaintiffs Comite de Jornaleros de Redondo Beach, National Day Laborer Organizing Network. Motion set for hearing on 11/28/2005 at 10:00 AM before Honorable Consuelo B. Marshall. (mg, ) (Entered: 10/19/2005)

NOTICE OF MOTION for Summary Judgment 75 filed by plaintiffs Comite de Jornaleros de Redondo Beach, National Day Laborer Organizing Network. Lodged statement of uncontroverted facts; proposed order (mg, ) (Entered: 10/19/2005)

DECLARATION of Araceli S Perez in support of plaintiffs MOTION for Summary Judgment 75 filed by plaintiffs Comite de Jornaleros de Redondo Beach, National Day Laborer Organizing Network. (mg, ) (Entered: 10/19/2005)

MINUTES by Judge Consuelo B. Marshall: On the Courts own motion, plaintiffs MOTION for Summary Judgment 75, and defendants MOTION for Summary Judgment 67 are hereby continued to 12/5/2005 at 10:00 AM before Honorable Consuelo B. Marshall. Opposition and statements of genuine issues shall be filed on or before 10/31/2005, Replies shall be due on or before 11/7/2005. Court Reporter: n/a. (mg, ) (Entered: 10/19/2005)

NOTICE of Association of Counsel associating attorneys Philip Hwang and Robert Rubin on behalf of Plaintiffs Comite de Jornaleros de Redondo Beach and National Day Laborer Organizing Network. Filed by plaintiffs. (mg, ) (Entered: 10/28/2005)

EXPARTE APPLICATION for Extension of Time for parties to file opposition briefs and reply briefs to Motions for summary judgment filed by plaintiffs Comite de Jornaleros de Redondo Beach, National Day Laborer Organizing Network. Lodged proposed order. (mg, ) (Entered: 10/31/2005)

ORDER by Judge Consuelo B. Marshall granting plaintiffs exp parte application extending time for opposition on plaintiffs MOTION for Summary Judgment 75 . Opposition due by 11/7/2005; Reply brief due by 11/14/2005. Motion will proceed as scheduled on 12/5/2005 at 10:00 AM before Honorable Consuelo B. Marshall.(mg, ) (Entered: 10/31/2005)

OPPOSITION to plaintiffs MOTION for Summary Judgment 75 ; Memorandum of points and authorities in support; Declaration of Eugene P Ramirez; filed by defendant Redondo Beach City of. (mg, ) (Entered: 11/01/2005)

OPPOSITION to plaintiffs Statement of Uncontroverted Facts and Conclusions of Law 76 filed by Defendant Redondo Beach City of. (mg, ) (Entered: 11/01/2005)

DECLARATION of Eugene P Ramirez re Objection to order granting plaintiffs EXPARTE APPLICATION for Extension of Time for Opposing Motion for Summary Judgment 81 filed by defendant Redondo Beach City of. (mg, ) (Entered: 11/01/2005)

PROOF OF SERVICE filed by defendant Redondo Beach City of, Opposition to Motion 82, Objections - non-motion 83, Declaration (Motion related) 84 ; served on 10/31/05. (mg, ) (Entered: 11/01/2005)

SUPPLEMENTAL DECLARATION of Eugene P Ramirez re Objection to Order Granting Plaintiffs EXPARTE APPLICATION for Extension of Time to File Opposition to Motion for Summary Judgment 81 filed by defendant Redondo Beach City of. (mg, ) (Entered: 11/04/2005)

PETITION of Araceli S Perez to Withdraw as Attorney for plaintiffs; filed by plaintiffs Comite de Jornaleros de Redondo Beach, National Day Laborer Organizing Network. Lodged proposed order. (mg, ) (Entered: 11/08/2005)

BRIEF IN OPPOSITION to defendants MOTION for Summary Judgment 75 filed by plaintiffs Comite de Jornaleros de Redondo Beach, National Day Laborer Organizing Network. (mg, ) (Entered: 11/09/2005)

OBJECTIONS TO DEFENDANTS EVIDENCE in support of its MOTION for Summary Judgment 75 filed by plaintiffs (mg, ) (Entered: 11/09/2005)

STATEMENT of Genuine Issues in response to defendants Statement of Uncontroverted Facts filed by Plaintiffs (mg, ) (Entered: 11/09/2005)

DECLARATION of Pablo Alvarado in support of plaintiffs Opposition to defendants MOTION for Summary Judgment 67 filed by plaintiffs (mg, ) (Entered: 11/09/2005)

PROOF OF SERVICE filed by plaintiffs re Brief in Opposition to Motion 88, Objections 89, Statement of genuine issues 90, Declaration (Motion related) 91, Declaration (Motion related) 92 ; served on 11/7/05. (mg, ) (Entered: 11/09/2005)

DECLARATION of Phillip Hwang in support of plaintiffs Opposition to defendants MOTION for Summary Judgment 67 filed by plaintiffs (mg, ) (Entered: 11/09/2005)