Case: Kohls v. Bonta

EXHIBITS re 1 Complaint by Christopher Kohls. (Attachments: # 1 Exhibit A. Governor Newsom tweet, # 2 Exhibit B. AB 2655 Timeline, # 3 Exhibit C. Assembly Committee on Judiciary Comments Report on AB 2655, # 4 Exhibit D. Senate Committee on Elections and Constitutional Amendments Comments on AB 2655, # 5 Exhibit E. Senate Judiciary Committee Comments on AB 2655, # 6 Exhibit F. AB 2839 Timeline, # 7 Exhibit G. Assembly Committee on Elections Comments on AB 2839, # 8 Exhibit H. Assembly Committee on Judiciary Comments Report on AB 2839, # 9 Exhibit I. Senate Judiciary Committee Comments on AB 2839, # 10 Exhibit J. Senate Standing Committee on Appropriations Comments on AB 2839) (Frank, Theodore) (Entered: 09/17/2024)

1 Exhibit A. Governor Newsom tweet

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2 Exhibit B. AB 2655 Timeline

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3 Exhibit C. Assembly Committee on Judiciary Comments Report on AB 2655

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4 Exhibit D. Senate Committee on Elections and Constitutional Amendments Comments

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5 Exhibit E. Senate Judiciary Committee Comments on AB 2655

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6 Exhibit F. AB 2839 Timeline

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7 Exhibit G. Assembly Committee on Elections Comments on AB 2839

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8 Exhibit H. Assembly Committee on Judiciary Comments Report on AB 2839

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9 Exhibit I. Senate Judiciary Committee Comments on AB 2839

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10 Exhibit J. Senate Standing Committee on Appropriations Comments on AB 2839

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COMPLAINT against All Defendants by Christopher Kohls. Attorney Frank, Theodore H. added. (Filing fee $ 405, receipt number ACAEDC-11754879) (Attachment(s): # 1 Civil Cover Sheet)(Frank, Theodore) (Entered: 09/17/2024)

1 Civil Cover Sheet

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MOTION for PRELIMINARY INJUNCTION by Christopher Kohls. (Attachments: # 1 Memorandum, # 2 Declaration of Theodore H. Frank, # 3 Proposed Order) (Frank, Theodore) Modified on 9/19/2024 (Nair, C). (Entered: 09/18/2024)

1 Memorandum

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2 Declaration of Theodore H. Frank

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3 Proposed Order

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PRO HAC VICE APPLICATION and PROPOSED ORDER submitted by Christopher Kohls for attorney Adam E. Schulman to appear Pro Hac Vice. (Filing fee $ 300, receipt number ACAEDC-11756018) (Attachments: # 1 Exhibit Certificate of Good Standing) (Frank, Theodore) (Entered: 09/18/2024)

1 Exhibit Certificate of Good Standing

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CIVIL NEW CASE DOCUMENTS ISSUED (Attachments: # 1 Consent Form, # 2 Order re Filing Requirements, # 3 VDRP) (Lopez, K) (Entered: 09/18/2024)

1 Consent Form

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2 Order re Filing Requirements

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3 VDRP

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SUMMONS ISSUED as to *Rob Bonta, Shirley N. Weber* with answer to complaint due within *21* days. Attorney *Theodore H. Frank* *Hamilton Lincoln Law Institute* *1629 K Street, NW Suite 300* *Washington, DC 20006*. (Lopez, K) (Entered: 09/18/2024)

PRO HAC VICE ORDER signed by Senior District Judge John A. Mendez on 09/18/2024 GRANTING 5 Application for Pro Hac Vice. Added attorney Adam E. Schulman, PHV for Christopher Kohls. The Pro Hac Vice attorney is directed to request electronic filing access through PACER. (Murphy, J) (Entered: 09/19/2024)

OPPOSITION by Rob Bonta, Shirley N. Weber to 6 Motion for Preliminary Injunction. (Attachments: # 1 Declaration of Kristin A. Liska (with Exhibits 1-7)) (Liska, Kristin) (Entered: 09/23/2024)

1 Declaration of Kristin A. Liska (with Exhibits 1-7)

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NOTICE of APPEARANCE by Kristin A. Liska on behalf of Rob Bonta, Shirley N. Weber. Attorney Liska, Kristin A. added. (Liska, Kristin) (Entered: 09/23/2024)

REPLY by Christopher Kohls to RESPONSE to 6 Motion for Preliminary Injunction. (Frank, Theodore) (Entered: 09/26/2024)

MINUTE ORDER (Text Only Entry) issued by M York Courtroom Deputy for Senior District Judge John A. Mendez on 09/27/2024: Upon careful review of Protect Democracy Project's Motion for Leave to File Amicus Curiae Brief (ECF No. 12 ), the Court DENIES the 12 motion. (York, M) (Entered: 09/27/2024)

Minute Order AND Order on Motion for Preliminary Injunction

Minute Order AND Order on Motion for Miscellaneous Relief

MOTION to FILE AMICUS CURIAE BRIEF re: 6 Motion for Preliminary Injunction by Protect Democracy Project. Attorney Langford, John added. (Attachments: # 1 Proposed Amicus Curiae Brief, # 2 Proposed Order) (Langford, John) Modified on 9/27/2024 (Benson, A.). (Entered: 09/27/2024)

1 Proposed Amicus Curiae Brief

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2 Proposed Order

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MINUTE ORDER (Text Only Entry) issued by M York Courtroom Deputy for Senior District Judge John A. Mendez on 09/27/2024: Plaintiff's 6 Motion for Preliminary Injunction is SUBMITTED without appearance and without oral argument pursuant to Local Rule 230(g). If the Court subsequently concludes that oral argument is necessary, a hearing will be set and the parties notified accordingly. (York, M) (Entered: 09/27/2024)

COMPLAINT filed by Plaintiffs The Babylon Bee, LLC and Kelly Chang Rickert. [FILED in Lead Case pursuant to 20 Order Consolidating Cases]. (Salmeron, A) (Entered: 10/25/2024)

ORDER signed by Senior District Judge John A. Mendez on 10/02/24 GRANTING 6 Motion for Preliminary Injunction. Defendants Rob Bonta and Shirley N. Weber and their agents, employees, public servants, officers and persons acting in concert with them are ENJOINED from enforcing AB 2839 except for the audio only severed portion of the statute. The bond requirement under Federal Rule 65(c) is WAIVED. (Benson, A.) (Entered: 10/02/2024)

[DISREGARD] -NOTICE of RELATED CASE(S) 2:24-cv-02787-WBS by The Babylon Bee, LLC, Kelly Chang Rickert. Attorney Chavez-Ochoa, Brian Ricardo added. (Chavez-Ochoa, Brian) Modified on 10/16/2024 (York, M). (Entered: 10/16/2024)

[DISREGARD - LOCAL COUNSEL TO REFILE] - NOTICE of RELATED CASE(S) 2:24-cv-02787-WBS-SCR by The Babylon Bee, LLC, Kelly Chang Rickert. Attorney Widmalm-Delphonse, Johannes added. (Widmalm-Delphonse, Johannes) Modified on 10/16/2024 (York, M). (Entered: 10/16/2024)

NOTICE of RELATED CASE(S) 2:24-cv-02787-WBS-SCR by Christopher Kohls. (Schulman, Adam) (Entered: 10/17/2024)

RELATED CASE ORDER signed by Senior District Judge John A. Mendez on 10/17/24 RELATING cases 2:24-cv-02527 JAM CKD and 2:24-cv-02787 JAM CKD. (Licea Chavez, V) (Entered: 10/18/2024)

STIPULATION and PROPOSED ORDER for Consolidation by Christopher Kohls. (Attachments: # 1 Proposed Order) (Schulman, Adam) (Entered: 10/22/2024)

1 Proposed Order

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ORDER FOR INJUNCTION signed by Senior District Judge John A. Mendez on 10/24/2024. [FILED in Lead Case per Chambers] (Salmeron, A) (Entered: 10/25/2024)

STIPULATION and ORDER signed by Senior District Judge John A. Mendez on 10/24/24, ORDERING that Pursuant to Fed. R. Civ. P. 42, the actions denominated as Kohls v. Bonta, et al. Case No. 2:24-cv-02527-JAM-CKD and The Babylon Bee, LLC, et al v. Feldstein Soto, et al., Case No. 2:24-cv-02787-JAM-CKD are hereby CONSOLIDATED. Case No. 2:24-cv-02527-JAM-CKD is designated as the "master file;" The Clerk is DIRECTED to add all complaints and answers filed in Case No. 2:24-cv-02787-JAM-CKD to the master file. The Clerk is DIRECTED to ADMINISTRATIVELY CLOSE Case No. 2:24-cv-02787-JAM-CKD. The parties are DIRECTED to file all future pleadings, motions and other filings ONLY in Case No. 2:24-cv-02527-JAM-CKD. (Salmeron, A) (Entered: 10/25/2024)

STIPULATION and PROPOSED ORDER for Summary Judgment Briefing Schedule by Kelly Chang Rickert, The Babylon Bee, LLC. (Widmalm-Delphonse, Johannes) (Entered: 11/13/2024)

COMPLAINT by X Corp. filed pursuant to 37 Order. [Originally filed in case no. 2:24-cv-3162] (Attachments: # 1 Civil Cover Sheet, # 2 Corporate Disclosure Statement) (Yin, K) (Entered: 12/27/2024)

1 Civil Cover Sheet

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2 Corporate Disclosure Statement

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STIPULATION and PROPOSED ORDER for Stay Enforcement of AB 2655 by Kelly Chang Rickert, The Babylon Bee, LLC. (Widmalm-Delphonse, Johannes) (Entered: 11/14/2024)

STIPULATION AND ORDER TO STAY ENFORCEMENT OF AB 2655 signed by Senior District Judge John A. Mendez on 11/15/2024. (York, M) (Entered: 11/15/2024)

ORDER FOR BRIEFING SCHEDULE ON SUMMARY JUDGMENT signed by Senior District Judge John A. Mendez on 11/15/2024 re 23 Stipulation. The Court ORDERS the following schedule:(1) Plaintiffs shall file their opening summary judgment briefs of no more than 25 pages each by 01/15/2025.(2) Defendants shall file a consolidated cross-motion for summary judgment and/or opposition brief of no more than 35 pages by 03/12/2025.(3) Plaintiffs shall each file their respective consolidated opposition and reply brief of no more than 25 pages by 04/11/2025(4) Defendants shall file their reply brief of no more than 15 pages by 05/02/2025. The motions will be SUBMITTED without appearance and without oral argument pursuant to Local Rule 230(g). If the Court subsequently concludes that oral argument is necessary, a hearing will be set and the parties notified accordingly. (York, M) (Entered: 11/16/2024)

COMPLAINT by Rumble Inc., et al., filed per 32 Order [ORIGINALLY FILED in 2:24-cv-3315 JAM CKD]. (Benson, A.) (Entered: 12/20/2024)

NOTICE of RELATED CASE(S) 2:24-cv-03315-DC-CKD, 2:24-cv-03162-WBS-CSK by Kelly Chang Rickert, The Babylon Bee, LLC. (Widmalm-Delphonse, Johannes) (Entered: 12/02/2024)

RELATED CASE ORDER signed by Senior District Judge John A. Mendez on 12/3/2024 RELATING case 2:24-cv-03315 DC-CKD; Reassigning the action to Judge John A. Mendez and Magistrate Judge Carolyn K. Delaney for all further proceedings. (Becknal, R.) (Entered: 12/04/2024)

NOTICE of RELATED CASE(S) 2:24-cv-03162-WBS-CSK, 24-cv-03315-JAM-CKD by X Corp.. Attorney Warne, William Ross added. (Warne, William) (Entered: 12/16/2024)

STIPULATION and PROPOSED ORDER for Consolidation by Kelly Chang Rickert, The Babylon Bee, LLC. (Widmalm-Delphonse, Johannes) (Entered: 12/19/2024)

STIPULATION and PROPOSED ORDER to Modify Summary Judgment Briefing Schedule by Kelly Chang Rickert, The Babylon Bee, LLC. (Widmalm-Delphonse, Johannes) Modified on 12/23/2024 (Benson, A.). (Entered: 12/20/2024)

STIPULATION and ORDER signed by Senior District Judge John A. Mendez on 12/19/24 CONSOLIDATING CASES 2:24-cv-2527 JAM CKD and 2:24-cv-3315 JAM CKD; DESIGNATING this case, 2:24-cv-2527 JAM CKD, as the Master File. Clerk to add all complaints and answers from 2:24-cv-3315 JAM CKD into this Master File and then administratively close that case. Parties are DIRECTED to file all future pleadings, motions, and other filings ONLY in this Case No. 2:24-cv-02527 JAM CKD. (Benson, A.) (Entered: 12/20/2024)

RELATED CASE ORDER signed by Senior District Judge John A. Mendez on 12/19/24 RELATING cases 2:24-cv-2527 JAM CKD, 2:24-cv-2787 JAM CKD, 2:24-cv-3315 JAM CKD and 2:24-cv-3162 JAM CKD. (Benson, A.) (Entered: 12/20/2024)

STIPULATION and PROPOSED ORDER for RE Consolidation by X Corp.. (Attachments: # 1 Proposed Order) (Warne, William) (Entered: 12/23/2024)

1 Proposed Order

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ORDER CONSOLIDATING CASES signed by Senior District Judge John A. Mendez on 12/26/2024. The actions denominated 2:24-cv-02527-JAM-CKD, 2:24-cv-03315-JAM-CKD, and 2:24-cv-03162-JAM-CKD are hereby CONSOLIDATED for all purposes. Case No. 2:24-cv-02527-JAM-CKD is designated as the "master file." The Clerk shall add all complaints and answers filed in Case Nos. 2:24-cv-03315-JAM-CKD and 2:24-cv-03162-JAM-CKD to the master file and ADMINISTRATIVELY CLOSE Case Nos. 2:24-cv-03315-JAM-CKD and 2:24-cv-03162-JAM-CKD. The parties are DIRECTED to file all future pleadings, motions, and other filings ONLY in Case No. 2:24-cv-02527-JAM-CKD. (Yin, K) (Entered: 12/27/2024)

STIPULATION AND ORDER signed by Senior District Judge John A. Mendez on 12/26/2024 ORDERING as follows: By 2/19/2025, Plaintiffs shall file their opening consolidated summary-judgment briefs; By 4/16/2025, Defendants shall file their consolidated cross-motions for summary judgment and/or opposition briefs; By 5/16/2025, Plaintiffs shall file their consolidated opposition and/or reply briefs. By 6/6/2025, Defendants shall file their consolidated reply briefs. (Mena-Sanchez, L) (Entered: 12/27/2024)

STIPULATION and PROPOSED ORDER for Amended Stay of Enforcement of AB 2655 by X Corp.. (Warne, William) (Entered: 01/02/2025)

ORDER signed by Senior District Judge John A. Mendez on 01/02/25 DIRECTING Defendants Rob Bonta and Shirly N. Weber to STAY enforcement of AB 2655 in its entirety, including §§ 20514(a) and 20515(a), through 06/28/25. (Deputy Clerk VLC) (Entered: 01/03/2025)

STIPULATION and PROPOSED ORDER for to Join Summary-Judgment Briefing Schedule by X Corp.. (Warne, William) (Entered: 01/07/2025)

STIPULATION and ORDER signed by Senior District Judge John A. Mendez on 1/10/2025 ORDERING that Plaintiff X Corp. follow the summary-judgment briefing schedule set forth at ECF No. 36 . (Deputy Clerk RRB) (Entered: 01/10/2025)

STIPULATION and PROPOSED ORDER to Modify Summary Judgment Briefing Schedule by X Corp.. (Warne, William) (Entered: 01/23/2025)

ORDER signed by Senior District Judge John A. Mendez on 01/30/25, per 43 Stipulation, MODIFYING the following dates: by 03/07/25, Plaintiffs and Defendants shall file their opening consolidated summary judgment briefs; by 06/06/25, Plaintiffs and Defendants shall file their consolidated responsive briefs. (Deputy Clerk AJB) (Entered: 01/31/2025)

DEFENDANTS' MOTION FOR SUMMARY JUDGMENT by Rob Bonta, Shirley N. Weber. Motion Hearing set for 8/5/2025 at 1:00 PM in Courtroom 6 (JAM) before Senior District Judge John A. Mendez. (Attachments: # 1 Memorandum, # 2 Memorandum, # 3 Declaration of R. Michael Alvarez, # 4 Declaration of Kristin A. Liska), # 5 Defendants' Statement of Undisputed Facts, # 6 Proposed Order)(Liska, Kristin) Modified on 3/12/2025 (AMW). (Entered: 03/07/2025)

1 Memorandum of Points and Authorities in Support of Defendants' Motion for

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2 Memorandum of Points and Authorities in Support of Defendants' Motion for

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3 Declaration of R. Michael Alvarez (with Exhibit 1)

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4 Declaration of Kristin A. Liska (with Exhibits 1-22)

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5 Defendants' Statement of Undisputed Facts

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6 Proposed Order

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NOTICE of REQUEST to SEAL Document(s) pursuant to L.R. 141 by Rumble Canada Inc., Rumble Inc., X Corp. (Kurtzberg, Joel) Modified on 3/12/2025 (AMW). (Entered: 03/07/2025)

STATEMENT of UNDISPUTED FACTS in support of 45, 46 Motions for Summary Judgment filed by Christopher Kohls, Kelly Chang Rickert, Rumble Canada Inc., Rumble Inc.. (Attachments: # 1 Declaration of Joel Kurtzberg, # 2 Exhibit AB 2655, # 3 Exhibit Hearing, # 4 Exhibit Assembly, # 5 Exhibit Senate, # 6 Exhibit Hearing on AB 2655, # 7 Exhibit Assembly Standing Committee, # 8 Exhibit Beat Biden,# 9 Exhibit Eliot Higgins, # 10 Exhibit @Kamala, # 11 Exhibit 57th, # 12 Exhibit Kamala Harris, # 13 Exhibit Elon Musk, # 14 Exhibit Gavin Newsom, # 15 Exhibit Hearing on AB 2655, # 16 Exhibit Wendy Seltzer, # 17 Exhibit Jennifer M. Urban, Joe Karaganis & Brianna Schofield, # 18 Exhibit Jennifer M. Urban & Laura Quilter, # 19 Exhibit Alfred C. Yen, # 20 Exhibit Donald J. Trump, # 21 Exhibit Floyd Abrams, # 22 Exhibit Assembly Committee on Judiciary, # 23 Exhibit Senate Judiciary Committee, # 24 Exhibit Senate Amended AB 2839, # 25 Exhibit Bill History, # 26 Exhibit 12 Minutes, # 27 Exhibit Frank J. Fleming, # 28 Exhibit Media on Demand, # 29 Declaration of Christopher Kohls, # 30 Declaration of Kelly Chang Rickert, # 31 Exhibit, # 32 Declaration of Seth Dillon, # 33 Exhibit)(Kurtzberg, Joel) Modified on 3/12/2025 (AMW). (Entered: 03/07/2025)

1 Declaration of Joel Kurtzberg

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2 Exhibit AB 2655

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3 Exhibit Hearing

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4 Exhibit Assembly

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5 Exhibit Senate

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6 Exhibit Hearing on AB 2655

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7 Exhibit Assembly Standing Committee

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8 Exhibit Beat Biden

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9 Exhibit Eliot Higgins

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10 Exhibit @Kamala

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11 Exhibit 57th

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12 Exhibit Kamala Harris

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13 Exhibit Elon Musk

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14 Exhibit Gavin Newsom

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15 Exhibit Hearing on AB 2655

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16 Exhibit Wendy Seltzer

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17 Exhibit Jennifer M. Urban, Joe Karaganis & Brianna Schofield

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18 Exhibit Jennifer M. Urban & Laura Quilter

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19 Exhibit Alfred C. Yen

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20 Exhibit Donald J. Trump

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21 Exhibit Floyd Abrams

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22 Exhibit Assembly Committee on Judiciary

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23 Exhibit Senate Judiciary Committee

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24 Exhibit Senate Amended AB 2839

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25 Exhibit Bill History

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26 Exhibit 12 Minutes

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27 Exhibit Frank J. Fleming

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28 Exhibit Media on Demand

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29 Declaration of Christopher Kohls

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30 Declaration of Kelly Chang Rickert

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31 Exhibit

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32 Declaration of Seth Dillon

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33 Exhibit

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PLAINTIFFS' MOTION FOR SUMMARY JUDGMENT by Christopher Kohls, Kelly Chang Rickert, The Babylon Bee, LLC, X Corp.. Motion Hearing set for 8/5/2025 at 1:00 PM in Courtroom 6 (JAM) before Senior District Judge John A. Mendez. (Attachments: # 1 Memorandum, # 2 Proposed Order)(Kurtzberg, Joel) Modified on 3/12/2025 (AMW). (Entered: 03/07/2025)

1 Memorandum in Support of Plaintiffs' Motion for Summary Judgment Against AB

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2 Proposed Order

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PLAINTIFFS' MOTION FOR SUMMARY JUDGMENT by Christopher Kohls, Kelly Chang Rickert, The Babylon Bee, LLC. Motion Hearing set for 8/5/2025 at 1:00 PM in Courtroom 6 (JAM) before Senior District Judge John A. Mendez. (Attachments: # 1 Memorandum, # 2 Proposed Order)(Widmalm-Delphonse, Johannes) Modified on 3/12/2025 (AMW). (Entered: 03/07/2025)

1 Memorandum

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2 Proposed Order

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REDACTED DECLARATION in support of 46 Motion for Summary Judgment filed by Plaintiffs. (Deputy Clerk KEZ) (Entered: 03/18/2025)

REDACTED DECLARATION in support of 46 Motion for Summary Judgment filed by Plaintiffs. (Deputy Clerk KEZ) (Entered: 03/18/2025)

SEALED EVENT (Attachments: # 1 Sealed Event, # 2 Sealed Event, # 3 Sealed Event, # 4 Sealed Event, # 5 Sealed Event, # 6 Sealed Event, # 7 Sealed Event, # 8 Sealed Event, # 9 Sealed Event, # 10 Sealed Event, # 11 Sealed Event, # 12 Sealed Event, # 13 Sealed Event, # 14 Sealed Event, # 15 Sealed Event, # 16 Sealed Event, # 17 Sealed Event, # 18 Sealed Event, # 19 Sealed Event, # 20 Sealed Event, # 21 Sealed Event, # 22 Sealed Event, # 23 Sealed Event, # 24 Sealed Event, # 25 Sealed Event, # 26 Sealed Event, # 27 Sealed Event, # 28 Sealed Event) (Deputy Clerk KEZ) (Entered: 03/18/2025)

ORDER signed by Senior District Judge John A. Mendez on 3/18/2025 GRANTING 48 Unopposed Request to Redact or Seal. (Deputy Clerk KEZ) (Entered: 03/18/2025)

NOTICE OF LODGING DOCUMENT(S) ELECTRONICALLY by Christopher Kohls, Kelly Chang Rickert, Rumble Canada Inc., Rumble Inc., The Babylon Bee, LLC, X Corp.: Exhibits 2, 5, 7, 9, 10, 11, 14, 25, and 27 of the Kurtzberg Declaration in Support of Plaintiffs' Motions for Summary Judgment. (Kurtzberg, Joel) (Entered: 03/19/2025)

ACKNOWLEDGEMENT OF RECEIPT of USB from Christopher Kohls- routed to File room. (Text only entry) (Deputy Clerk VLC) (Entered: 03/20/2025)

REDACTED DECLARATION in support of 46 Motion for Summary Judgment. (Attachments: # 1 Exhibit 1 - Elected Officials California State Assembly, # 2 Exhibit 2 - BallotPedia Cities in California, # 3 Exhibit 3 - Global Affairs, X, # 4 Exhibit 4 - Authenticity, X, # 5 Exhibit 5 - Journal of the American Medical Association Article, # 6 Exhibit 6 - Forbes Article, # 7 Exhibit 7 - Renault Article, # 8 Exhibit 8 - Chuai Article, # 9 Exhibit 9 - Drolsbach Research Report, # 10 Exhibit 10 - Community Notes, # 11 Exhibit 11 - MyLordBebo Post, # 12 Exhibit 12 - Brookebay21 Post, # 13 Exhibit 13 - How to Identify AI Content on Meta Products, # 14 Exhibit 14 - Disclosing Use of Altered or Synthetic Content, YouTube, # 15 Exhibit 15 - About AI-Generated Content, TikTok, # 16 Exhibit 16 - Generative AI on Snapchat, # 17 Exhibit 17 - Google Search's Guidance About AI-Generated Content, # 18 Exhibit 18 - Civic Integrity Policy, X, # 19 Exhibit 19 - Misinformation, Meta, # 20 Exhibit 20 - Elections Misinformation Policies, YouTube, # 21 Exhibit 21 - Protecting Election Integrity in 2024, TikTok, # 22 Exhibit 22 - Harmful False or Deceptive Practices, Snapchat, # 23 Exhibit 23 - Political Content, Google Search)(Kurtzberg, Joel) (Entered: 03/21/2025)

MINUTE ORDER (Text Only Entry) issued by Courtroom Deputy for Senior District Judge John A. Mendez on 03/27/2025: The Court hereby GRANTS NetChoice's Consent Motion for Leave to Appear as Amicus Curiae in support of Plaintiffs' Motion for Summary Judgment. (ECF No. 57 ). NetChoice shall refile the Amicus Brief, attached to the motion as "Exhibit A," within five (5) days of this order. Amici curiae is advised that the Court will only consider briefing that helps the Court beyond the help the lawyers for the parties are able to provide; duplicative or cumulative arguments will not be considered. (Deputy Clerk MDY) (Entered: 03/27/2025)

Minute Order AND Order on Motion for Miscellaneous Relief

MOTION Leave to Appear as Amicus Curiae by NetChoice. Attorney Benbrook, Bradley A. added. (Attachments: # 1 Exhibit Proposed Amicus Brief, # 2 Proposed Order)(Benbrook, Bradley) (Entered: 03/27/2025)

1 Exhibit Proposed Amicus Brief

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2 Proposed Order

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AMICUS CURIAE BRIEF in SUPPORT of Plaintiffs' 49 Motion for Summary Judgment filed by NetChoice. (Benbrook, Bradley) (Entered: 03/28/2025)

PRO HAC VICE APPLICATION and PROPOSED ORDER submitted by NetChoice for attorney Joshua P. Morrow to appear Pro Hac Vice. (Filing fee $ 300, receipt number ACAEDC-12124992) (Attachments: # 1 Exhibit Certificate of Good Standing) (Benbrook, Bradley) (Entered: 03/28/2025)

PRO HAC VICE APPLICATION and PROPOSED ORDER submitted by NetChoice for attorney Jeremy Evan Maltz to appear Pro Hac Vice. (Filing fee $ 300, receipt number ACAEDC-12124990) (Attachments: # 1 Exhibit Certificate of Good Standing) (Benbrook, Bradley) (Entered: 03/28/2025)

PRO HAC VICE APPLICATION and PROPOSED ORDER submitted by NetChoice for attorney Scott A. Keller to appear Pro Hac Vice. (Filing fee $ 300, receipt number ACAEDC-12124987) (Attachments: # 1 Exhibit Scott A. Keller) (Benbrook, Bradley) (Entered: 03/28/2025)

PRO HAC VICE APPLICATION and PROPOSED ORDER submitted by NetChoice for attorney Steven P. Lehotsky to appear Pro Hac Vice. (Filing fee $ 300, receipt number ACAEDC-12124983) (Attachments: # 1 Exhibit Certificate of Good Standing) (Benbrook, Bradley) (Entered: 03/28/2025)

ORDER signed by Senior District Judge John A. Mendez on 04/02/25 GRANTING 62 Application for Pro Hac Vice. Added attorney Joshua P. Morrow, PHV for NetChoice. The Pro Hac Vice attorney is directed to request electronic filing access through PACER. (Deputy Clerk VLC) (Entered: 04/03/2025)

ORDER signed by Senior District Judge John A. Mendez on 04/02/25 GRANTING 61 Application for Pro Hac Vice. Added attorney Jeremy Evan Maltz, PHV for NetChoice. The Pro Hac Vice attorney is directed to request electronic filing access through PACER. (Deputy Clerk VLC) (Entered: 04/03/2025)

ORDER signed by Senior District Judge John A. Mendez on 04/02/25 GRANTING 60 Application for Pro Hac Vice. Added attorney Scott A. Keller, PHV for NetChoice. The Pro Hac Vice attorney is directed to request electronic filing access through PACER. (Deputy Clerk VLC) (Entered: 04/03/2025)

ORDER signed by Senior District Judge John A. Mendez on 04/02/25 GRANTING 59 Application for Pro Hac Vice. Added attorney Steven P. Lehotsky, PHV for NetChoice. The Pro Hac Vice attorney is directed to request electronic filing access through PACER. (Deputy Clerk VLC) (Entered: 04/03/2025)

MOTION to INTERVENE as Amicus Curiae by Electronic Privacy Information Center. (Attachments: # 1 Proposed Order, # 2 Proposed Amicus Brief)(Butler, Alan) (Entered: 04/18/2025)

2

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PRO HAC VICE APPLICATION and PROPOSED ORDER submitted by Electronic Privacy Information Center for attorney Mason Kortz to appear Pro Hac Vice. Attorney Butler, Alan added. (Filing fee $ 300, receipt number ACAEDC-12167464) (Attachments: # 1 Exhibit Certificate of Good Standing) (Butler, Alan) (Entered: 04/18/2025)

MINUTE ORDER (Text Only Entry) issued by Courtroom Deputy for Senior District Judge John A. Mendez on 04/21/2025: The Court hereby GRANTS Electronic Privacy Information Center's Consent Motion for Leave to File Brief as Amicus Curiae in support of Defendants' Motion for Summary Judgment. (ECF No. 69 ). Electronic Privacy Information Center shall refile the Amicus Brief, attached to the motion at ECF No. 69 -2, within five (5) days of this order. Amici curiae is advised that the Court will only consider briefing that helps the Court beyond the help the lawyers for the parties are able to provide; duplicative or cumulative arguments will not be considered. (Deputy Clerk MDY) (Entered: 04/21/2025)

Minute Order AND Order on Motion to Intervene

PRO HAC VICE ORDER signed by Senior District Judge John A. Mendez on 04/18/25 GRANTING 68 Application for Pro Hac Vice. Added Attorney Mason A. Kortz, PHV for Electronic Privacy Information Center. The Pro Hac Vice Attorney is directed to request electronic filing access through PACER. (Deputy Clerk KML) (Entered: 04/21/2025)

AMICUS CURIAE BRIEF in SUPPORT of Defendants 49 Motion for Summary Judgment filed by Electronic Privacy Information Center. (Kortz, Mason) Modified on 4/23/2025 (KML). (Entered: 04/22/2025)

CORPORATE DISCLOSURE STATEMENT by Plaintiff X Corp.. (Kurtzberg, Joel) (Entered: 05/22/2025)

NOTICE of ERRATA by Christopher Kohls, Kelly Chang Rickert, The Babylon Bee, LLC re 45 Motion for Summary Judgment. (Attachments: # 1 [Corrected] Plaintiffs Memorandum in Support of Motion for Summary Judgment Against AB 2839)(Widmalm-Delphonse, Johannes) (Entered: 05/28/2025)

MOTION for Leave to file amicus curiae brief by Campaign Legal Center. Attorney McAllen, Megan Patricia added. (Attachments: # 1 Proposed Amicus Brief, # 2 Proposed Order)(McAllen, Megan) Modified on 6/5/2025 (KEZ). (Entered: 06/04/2025)

Response

Minute Order AND Order on Motion for Miscellaneous Relief AND ~Util - 1 Set/Reset Deadlines and Hearings

Opposition to Motion

Opposition to Motion

Response

Opposition to Motion

Response

Brief

MINUTE ORDER (Text Only Entry) issued by Courtroom Deputy for Senior District Judge John A. Mendez on 06/06/2025: The Court hereby GRANTS Campaign Legal Center's Motion for Leave to File Brief as Amicus Curiae in Support of Defendants' Motion for Summary Judgment (ECF No. 75 ). Campaign Legal Center shall refile the Amicus Brief, attached to the motion at ECF No. 75 -1, within five (5) days of this order. Amici curiae is advised that the Court will only consider briefing that helps the Court beyond the help the lawyers for the parties are able to provide; duplicative or cumulative arguments will not be considered. (Deputy Clerk MDY) (Entered: 06/06/2025)

Pro Hac Vice Application

PRO HAC VICE ORDER signed by Senior District Judge John A. Mendez on 6/12/2025 GRANTING 84 Application for Pro Hac Vice. Added attorney Elizabeth D. Shimek, PHV for Campaign Legal Center. The Pro Hac Vice attorney is directed to request electronic filing access through PACER. (Deputy Clerk AMW)

STIPULATION and ORDER signed by Senior District Judge John A. Mendez on 6/24/25 DIRECTING defendants Bonta and Weber to STAY Enforcement of AB 2655 in it's entirety, including 20514(a) and 20515(a) through 10/25/25. (Deputy Clerk AMW)

Supplement

Request

ORDER signed by Senior District Judge John A. Mendez on 7/23/2025 GRANTING 89 Unopposed Request and ORDERS that the information regarding the recent addition to Plaintiff X-Corp's Community Notes program is hereby part of the summary judgment record and may be considered in connection with the parties' cross-motions for summary judgment. (Deputy Clerk OML) (Entered: 07/24/2025)

NOTICE OF SUPPLEMENTAL AUTHORITY by Rumble Canada Inc., Rumble Inc., X Corp. re 45, 46, and 49 Motions for Summary Judgment. (Kurtzberg, Joel) (Entered: 07/24/2025)

NOTICE OF SUPPLEMENTAL AUTHORITY by Rumble Canada Inc., Rumble Inc., X Corp. (Kurtzberg, Joel) (Entered: 07/29/2025)

MINUTES (Text Only) for MOTION HEARING re Cross-Motions for Summary Judgment (ECF Nos. 45, 46, and 49 before Senior District Judge John A. Mendez held on 08/05/2025. Plaintiffs' counsel Joel Kurtzberg (Lead arguing for AB 2655), Johannes Widmalm-Delphonse (Lead, arguing for AB 2839), Floyd Abrams, Theodore Frank, Brian Chavez-Ochoa, Jonathan Scruggs, and Mathew Hoffmann, all present. Defense counsel, Kristin Liska, present. The Court and counsel discussed the pending Plaintiffs' 46 Motion for Summary Judgment Against Assembly Bill 2655, and Defendants' 49 Cross-Motion for Summary Judgment on AB 2655. Arguments heard. After careful consideration, and for the reasons stated on the record, the Court GRANTED Plaintiffs' Motion for Summary Judgment Against AB 2655 (ECF No. 46 ) and DENIED Defendants' Cross-Motion for Summary Judgment on AB 2655 (ECF No. 49 ). As stated on the record, Plaintiffs' counsel shall, withing two (2) weeks, submit a proposed order, pre-approved by defense counsel. The Court and counsel discussed the pending Plaintiffs' 45 Motion for Summary Judgment Against Assembly Bill 2839, and Defendants' 49 Cross-Motion for Summary Judgment on AB 2839. Arguments heard. After careful consideration, and for the reasons stated on the record, the Court SUBMITTED Plaintiffs' Motion for Summary Judgment Against Assembly Bill 2839 (ECF No. 45 ), and Defendants' Cross-Motion for Summary Judgment on AB 2839 (ECF No. 49 ). A written order will issue. Court Reporter: Kimberly Bennett. (Deputy Clerk MDY) (Entered: 08/05/2025)

Motion Hearing AND Order on Motion for Summary Judgment AND Order on Motion for Summary Judgment AND Order on Motion for Summary Judgment

TRANSCRIPT REQUEST by Rob Bonta, Shirley N. Weber for proceedings held on August 5, 2025 before Judge Senior District Judge John A. Mendez. Court Reporter Kimberly Bennett. (Liska, Kristin) (Entered: 08/06/2025)

TRANSCRIPT REQUEST by X Corp. for proceedings held on August 5, 2025 before Judge Hon. John A. Mendez. Court Reporter Kimberly Bennett. (Warne, William) (Entered: 08/07/2025)