Case: California Rifle and Pistol Association, Incorporated v. Los Angeles County Sheriffs Department

Legal Defense Fund

COMPLAINT Receipt No: ACACDC-36508137 - Fee: $405, filed by Plaintiffs Cynthia Gabaldon, Charles Messel, The Second Amendment Foundation, California Rifle & Pistol Association, Incorporated, Erick Velasquez, Gun Owners of America, Inc., Clarence Rigali, Stephen Hoover, Brian Weimer, Gun Owners Foundation, Keith Reeves, Gun Owners of California, Inc.. (Attorney Carl Dawson Michel added to party California Rifle & Pistol Association, Incorporated(pty:pla), Attorney Carl Dawson Michel added to party Cynthia Gabaldon(pty:pla), Attorney Carl Dawson Michel added to party Gun Owners Foundation(pty:pla), Attorney Carl Dawson Michel added to party Gun Owners of America, Inc.(pty:pla), Attorney Carl Dawson Michel added to party Gun Owners of California, Inc.(pty:pla), Attorney Carl Dawson Michel added to party Stephen Hoover(pty:pla), Attorney Carl Dawson Michel added to party Charles Messel(pty:pla), Attorney Carl Dawson Michel added to party Keith Reeves(pty:pla), Attorney Carl Dawson Michel added to party Clarence Rigali(pty:pla), Attorney Carl Dawson Michel added to party Erick Velasquez(pty:pla), Attorney Carl Dawson Michel added to party Brian Weimer(pty:pla))(Michel, Carl) (Entered: 12/04/2023)

CIVIL COVER SHEET filed by Plaintiffs California Rifle & Pistol Association, Incorporated, Cynthia Gabaldon, Gun Owners Foundation, Gun Owners of America, Inc., Gun Owners of California, Inc., Stephen Hoover, Charles Messel, Keith Reeves, Clarence Rigali, The Second Amendment Foundation, Erick Velasquez, Brian Weimer. (Michel, Carl) (Entered: 12/04/2023)

Request for Clerk to Issue Summons on Complaint (Attorney Civil Case Opening),,,, 1 filed by Plaintiffs California Rifle & Pistol Association, Incorporated, Cynthia Gabaldon, Gun Owners Foundation, Gun Owners of America, Inc., Gun Owners of California, Inc., Stephen Hoover, Charles Messel, Keith Reeves, Clarence Rigali, The Second Amendment Foundation, Erick Velasquez, Brian Weimer. (Michel, Carl) (Entered: 12/04/2023)

NOTICE of Interested Parties filed by Plaintiffs All Plaintiffs, (Michel, Carl) (Entered: 12/04/2023)

CORPORATE DISCLOSURE STATEMENT filed by Plaintiff California Rifle & Pistol Association, Incorporated (Michel, Carl) (Entered: 12/04/2023)

NOTICE OF ASSIGNMENT to District Judge Sherilyn Peace Garnett and Magistrate Judge Autumn D. Spaeth. (lh) (Entered: 12/05/2023)

NOTICE TO PARTIES OF COURT-DIRECTED ADR PROGRAM filed. (lh) (Entered: 12/05/2023)

Notice to Counsel Re Consent to Proceed Before a United States Magistrate Judge. (lh) (Entered: 12/05/2023)

21 DAY Summons Issued re Complaint (Attorney Civil Case Opening), 1 as to Defendants Robert Bonta, Colleen Flores, La Verne Police Department, Los Angeles County Sheriffs Department, Robert Luna. (lh) (Entered: 12/05/2023)

ORDER RE TRANSFER to this Court's General Order in the Matter of Assignment of Cases and Duties to the District Judges. (Related Case) filed. Transfer of case declined by Judge Cormac J. Carney, for the reasons set forth on this order. Related Case No. 8:23-cv-01696 CJC(ADSx) (rn) (Entered: 12/06/2023)

PROOF OF SERVICE Executed by Plaintiff Cynthia Gabaldon, Charles Messel, The Second Amendment Foundation, California Rifle and Pistol Association, Incorporated, Erick Velasquez, Gun Owners of America, Inc., Clarence Rigali, Stephen Hoover, Brian Weimer, Gun Owners Foundation, Keith Reeves, Gun Owners of California, Inc., upon Defendant Robert Bonta served on 12/6/2023, answer due 12/27/2023. Service of the Summons and Complaint were executed upon Robert Bonta, in his official capacity as Attorney General of the State of California in compliance with Federal Rules of Civil Procedure by personal service (Michel, Carl) (Entered: 12/15/2023)

PROOF OF SERVICE Executed by Plaintiff Cynthia Gabaldon, Charles Messel, The Second Amendment Foundation, California Rifle and Pistol Association, Incorporated, Erick Velasquez, Gun Owners of America, Inc., Clarence Rigali, Stephen Hoover, Brian Weimer, Gun Owners Foundation, Keith Reeves, Gun Owners of California, Inc., upon Defendant Colleen Flores served on 12/11/2023, answer due 1/2/2024. Service of the Summons and Complaint were executed upon La Verne Chief of Police Coleen Flores in her Official Capacity in compliance with Federal Rules of Civil Procedure by personal service (Michel, Carl) (Entered: 12/15/2023)

PROOF OF SERVICE Executed by Defendant Cynthia Gabaldon, Charles Messel, The Second Amendment Foundation, California Rifle and Pistol Association, Incorporated, Erick Velasquez, Gun Owners of America, Inc., Clarence Rigali, Stephen Hoover, Brian Weimer, Gun Owners Foundation, Keith Reeves, Gun Owners of California, Inc., upon Defendant La Verne Police Department served on 12/11/2023, answer due 1/2/2024. Service of the Summons and Complaint were executed upon La Verne Police Department in compliance with Federal Rules of Civil Procedure by personal service (Michel, Carl) (Entered: 12/15/2023)

PROOF OF SERVICE Executed by Plaintiff Cynthia Gabaldon, Charles Messel, The Second Amendment Foundation, California Rifle and Pistol Association, Incorporated, Erick Velasquez, Gun Owners of America, Inc., Clarence Rigali, Stephen Hoover, Brian Weimer, Gun Owners Foundation, Keith Reeves, Gun Owners of California, Inc., upon Defendant Los Angeles County Sheriffs Department served on 12/11/2023, answer due 1/2/2024. Service of the Summons and Complaint were executed upon Los Angeles County Sheriff's Department in compliance with Federal Rules of Civil Procedure by personal service (Michel, Carl) (Entered: 12/15/2023)

PROOF OF SERVICE Executed by Plaintiff Cynthia Gabaldon, Charles Messel, The Second Amendment Foundation, California Rifle and Pistol Association, Incorporated, Erick Velasquez, Gun Owners of America, Inc., Clarence Rigali, Stephen Hoover, Brian Weimer, Gun Owners Foundation, Keith Reeves, Gun Owners of California, Inc., upon Defendant Robert Luna served on 12/11/2023, answer due 1/2/2024. Service of the Summons and Complaint were executed upon Sheriff Robert Luna in his Official Capacity in compliance with Federal Rules of Civil Procedure by personal service (Michel, Carl) (Entered: 12/15/2023)

STIPULATION for Extension of Time to File Response as to Complaint (Attorney Civil Case Opening),,,, 1 filed by Defendant Robert Bonta. (Attachments: # 1 Proposed Order)(Attorney Christina Rae Burgart Lopez added to party Robert Bonta(pty:dft))(Lopez, Christina) (Entered: 12/21/2023)

1 Proposed Order

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ORDER RE: EXTENDING TIME TO RESPOND TO COMPLAINT 16 by Judge Sherilyn Peace Garnett. After full consideration, and good cause appearing, the Parties' request is GRANTED. Within twenty-one days after the Court's Order on Plaintiffs' forthcoming motion for preliminary injunctive relief, Defendants will respond to the Complaint. (rolm) (Entered: 12/26/2023)

NOTICE of Appearance filed by attorney Jane Elizabeth Reilley on behalf of Defendant Robert Bonta (Attorney Jane Elizabeth Reilley added to party Robert Bonta(pty:dft))(Reilley, Jane) (Entered: 01/25/2024)

NOTICE TO FILER OF DEFICIENCIES in Electronically Filed Document RE: Notice of Appearance 18 . The following error(s) was/were found: Incorrect event selected. Correct event to be used is: Notice of Appearance or Withdrawal of Counsel G123.. Case number incomplete; missing initials of Judge In response to this notice, the Court may: (1) order an amended or correct document to be filed; (2) order the document stricken; or (3) take other action as the Court deems appropriate. You need not take any action in response to this notice unless and until the Court directs you to do so. (ak) (Entered: 01/26/2024)

NOTICE OF MOTION AND MOTION for Preliminary Injunction filed by Plaintiffs California Rifle and Pistol Association, Incorporated, Cynthia Gabaldon, Gun Owners Foundation, Gun Owners of America, Inc., Gun Owners of California, Inc., Stephen Hoover, Charles Messel, Keith Reeves, Clarence Rigali, The Second Amendment Foundation, Erick Velasquez, Brian Weimer. Motion set for hearing on 3/13/2024 at 01:30 PM before Judge Sherilyn Peace Garnett. (Attachments: # 1 Memorandum of Points & Authorities, # 2 Request for Judicial Notice, # 3 Exhibit A to RJN - Cumberland County Pennsylvania License to Carry Firearms Webpage, # 4 Exhibit B to RJN - La Verne Police Department CCW Fee Schedule, # 5 Exhibit C to RJN - Arizona Department of Public Safety Concealed Weapons and Permits Webpage, # 6 Exhibit D to RJN - Texas Department of Public Safety, License to Carry (LTC) Fee Table, # 7 Exhibit E to RJN - Utah Department of Public Safety How Do I Apply Webpage, # 8 Exhibit F to RJN - Washington Department of Licensing Fees, Firearm Dealers Webpage, # 9 Exhibit G to RJN - LA County Sheriffs Department Concealed Carry Weapon License, Permitium, # 10 Exhibit H to RJN - Glendora Police Department License to Carry a Concealed Weapon, Permitium, # 11 Exhibit I to RJN - La Verne Police Department Information on Psychological Assessment, # 12 Exhibit J to RJN - Fred L. Button, ed., General Municipal Ordinances of the City of Oakland, CA, # 13 Exhibit K to RJN - Prohibiting the Carrying of Concealed Deadly Weapons, Ordinance no. 84, # 14 Declaration of Konstadinos T. Moros, # 15 Declaration of Richard Minnich, # 16 Declaration of Brian Weimer, # 17 Declaration of Charles Messel, # 18 Declaration of Clarence Rigali, # 19 Declaration of Cynthia Gabaldon, # 20 Declaration of David Broady, # 21 Declaration of Erick Velasquez, # 22 Declaration of Jack Skadsem, # 23 Declaration of Jim Carlson, # 24 Declaration of Keith Reeves, # 25 Declaration of Sherwin David Parowashraf, # 26 Declaration of Stephen Hoover, # 27 Declaration of Woodrow Stalter, # 28 Proposed Order) (Michel, Carl) (Entered: 01/26/2024)

1 Memorandum of Points & Authorities

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2 Request for Judicial Notice

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3 Exhibit A to RJN - Cumberland County Pennsylvania License to Carry Firearms Webp

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4 Exhibit B to RJN - La Verne Police Department CCW Fee Schedule

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5 Exhibit C to RJN - Arizona Department of Public Safety Concealed Weapons and Per

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6 Exhibit D to RJN - Texas Department of Public Safety, License to Carry (LTC) Fee

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7 Exhibit E to RJN - Utah Department of Public Safety How Do I Apply Webpage

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8 Exhibit F to RJN - Washington Department of Licensing Fees, Firearm Dealers Web

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9 Exhibit G to RJN - LA County Sheriffs Department Concealed Carry Weapon License

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10 Exhibit H to RJN - Glendora Police Department License to Carry a Concealed Weapo

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11 Exhibit I to RJN - La Verne Police Department Information on Psychological Asses

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12 Exhibit J to RJN - Fred L. Button, ed., General Municipal Ordinances of the City

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13 Exhibit K to RJN - Prohibiting the Carrying of Concealed Deadly Weapons, Ordina

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14 Declaration of Konstadinos T. Moros

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15 Declaration of Richard Minnich

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16 Declaration of Brian Weimer

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17 Declaration of Charles Messel

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18 Declaration of Clarence Rigali

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19 Declaration of Cynthia Gabaldon

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20 Declaration of David Broady

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21 Declaration of Erick Velasquez

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22 Declaration of Jack Skadsem

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23 Declaration of Jim Carlson

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24 Declaration of Keith Reeves

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25 Declaration of Sherwin David Parowashraf

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26 Declaration of Stephen Hoover

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27 Declaration of Woodrow Stalter

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28 Proposed Order

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Joint STIPULATION for Order to Extend Page Limit of Plaintiffs' Reply Brief filed by Plaintiffs California Rifle and Pistol Association, Incorporated, Cynthia Gabaldon, Gun Owners Foundation, Gun Owners of America, Inc., Gun Owners of California, Inc., Stephen Hoover, Charles Messel, Keith Reeves, Clarence Rigali, The Second Amendment Foundation, Erick Velasquez, Brian Weimer. (Attachments: # 1 Proposed Order)(Moros, Konstadinos) (Entered: 02/06/2024)

1 Proposed Order

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ORDER EXTENDING PAGE LIMIT OF PLAINTIFFS' REPLY BRIEF by Judge Sherilyn Peace Garnett, re Stipulation 21 : After full consideration, and good cause appearing, the Parties' request is GRANTED. Plaintiffs' reply brief shall be no longer than 30 pages. (bm) (Entered: 02/09/2024)

OPPOSITION TO re: NOTICE OF MOTION AND MOTION for Preliminary Injunction 20 filed by Defendants Colleen Flores, La Verne Police Department. (Attachments: # 1 Declaration Chief Colleen Flores In Support of Opposition, # 2 Declaration Acting Chief Sam Gonzalez In Support of Opposition, # 3 Exhibit 1 (Matrix) to Declaration of Acting Chief Sam Gonzalez In Support of Opposition, # 4 Declaration Lt. Chris Dransfeldt In Support of Oppoiition, # 5 Exhibit 1 (Matrix) to Declaration of Lt. Chris Dransfeldt In Support of Opposition)(Attorney Bruce A Lindsay added to party Colleen Flores(pty:dft), Attorney Bruce A Lindsay added to party La Verne Police Department(pty:dft))(Lindsay, Bruce) (Entered: 02/21/2024)

1 Declaration Chief Colleen Flores In Support of Opposition

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2 Declaration Acting Chief Sam Gonzalez In Support of Opposition

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3 Exhibit 1 (Matrix) to Declaration of Acting Chief Sam Gonzalez In Support of Opp

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4 Declaration Lt. Chris Dransfeldt In Support of Oppoiition

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5 Exhibit 1 (Matrix) to Declaration of Lt. Chris Dransfeldt In Support of Oppositi

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OBJECTIONS TO EVIDENCE re: NOTICE OF MOTION AND MOTION for Preliminary Injunction 20 filed by Defendants Colleen Flores, La Verne Police Department. (Lindsay, Bruce) (Entered: 02/21/2024)

Opposition re: NOTICE OF MOTION AND MOTION for Preliminary Injunction 20 filed by Defendant Robert Bonta. (Attachments: # 1 Declaration of R. Spitzer, # 2 Declaration of M. Vorenberg, # 3 Declaration of B. Rivas)(Lopez, Christina) (Entered: 02/21/2024)

1 Declaration of R. Spitzer

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2 Declaration of M. Vorenberg

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3 Declaration of B. Rivas

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Notice of Appearance or Withdrawal of Counsel: for attorney Mark D. Selwyn counsel for Defendants Los Angeles County Sheriffs Department, Robert Luna. Adding Mark Selwyn as counsel of record for Los Angeles County Sheriff's Department and Sheriff Robert Luna for the reason indicated in the G-123 Notice. Filed by Defendants Los Angeles County Sheriff's Department and Sheriff Robert Luna. (Attorney Mark D. Selwyn added to party Los Angeles County Sheriffs Department(pty:dft), Attorney Mark D. Selwyn added to party Robert Luna(pty:dft))(Selwyn, Mark) (Entered: 02/21/2024)

OPPOSITION re: NOTICE OF MOTION AND MOTION for Preliminary Injunction 20 filed by Defendants Los Angeles County Sheriffs Department, Robert Luna. (Attachments: # 1 Declaration of Regina R. Chavez in Support, # 2 Exhibit 1 - Los Angeles Sheriff's Department's denial of Mr. Velasquez's Application to Carry a Concealed Weapon, # 3 Exhibit 2 - Police Reports Retrieved, # 4 Declaration of Ryan Chabot in Support, # 5 Exhibit 1 - Request for a Domestic Violence Restraining Order against Sherwin David Partowashraf, # 6 Exhibit 2 - Temporary Restraining Order restraining Sherwin David Partowashraf, # 7 Exhibit 3 - Superior Court of California's July 18, 2022 minutes, # 8 Request for Judicial Notice, # 9 Survey of Historical License Requirement, # 10 Compendium of Historical Laws, # 11 Proposed Order)(Selwyn, Mark) (Entered: 02/21/2024)

1 Declaration of Regina R. Chavez in Support

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2 Exhibit 1 - Los Angeles Sheriff's Department's denial of Mr. Velasque

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3 Exhibit 2 - Police Reports Retrieved

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4 Declaration of Ryan Chabot in Support

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5 Exhibit 1 - Request for a Domestic Violence Restraining Order against Sherwin D

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6 Exhibit 2 - Temporary Restraining Order restraining Sherwin David Partowashraf

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7 Exhibit 3 - Superior Court of California's July 18, 2022 minutes

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8 Request for Judicial Notice

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9 Survey of Historical License Requirement

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10 Compendium of Historical Laws

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11 Proposed Order

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Notice of Appearance or Withdrawal of Counsel: for attorney Henry Michael Nikogosyan counsel for Defendants Los Angeles County Sheriffs Department, Robert Luna. Adding Henry Nikogosyan as counsel of record for Los Angeles County Sheriff's Department and Sheriff Robert Luna for the reason indicated in the G-123 Notice. Filed by Defendants Los Angeles County Sheriff's Department and Sheriff Robert Luna. (Attorney Henry Michael Nikogosyan added to party Los Angeles County Sheriffs Department(pty:dft), Attorney Henry Michael Nikogosyan added to party Robert Luna(pty:dft))(Nikogosyan, Henry) (Entered: 02/22/2024)

CERTIFICATE of Interested Parties filed by Defendants Colleen Flores, La Verne Police Department, (Lindsay, Bruce) (Entered: 02/22/2024)

JOINDER filed by Defendants Colleen Flores, La Verne Police Department joining in Objection/Opposition (Motion related), 25 . (Lindsay, Bruce) (Entered: 02/22/2024)

APPLICATION of Non-Resident Attorney Ryan M. Chabot to Appear Pro Hac Vice on behalf of Defendants Los Angeles County Sheriffs Department, Robert Luna (Pro Hac Vice Fee - $500 Fee Paid, Receipt No. ACACDC-36968948) filed by Defendants Los Angeles County Sheriffs Department, Robert Luna. (Attachments: # 1 Proposed Order) (Nikogosyan, Henry) (Entered: 02/23/2024)

1 Proposed Order

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REPLY in Support of NOTICE OF MOTION AND MOTION for Preliminary Injunction 20 filed by Plaintiffs California Rifle and Pistol Association, Incorporated, Cynthia Gabaldon, Gun Owners Foundation, Gun Owners of America, Inc., Gun Owners of California, Inc., Stephen Hoover, Charles Messel, Keith Reeves, Clarence Rigali, The Second Amendment Foundation, Erick Velasquez, Brian Weimer. (Attachments: # 1 Declaration of Clayton Cramer in Support of Plaintiffs' Motion for Preliminary Injunction, # 2 Exhibit 1 to Declaration of Clayton Cramer, # 3 Exhibit 2 to Declaration of Clayton Cramer, # 4 Exhibit 3 to Declaration of Clayton Cramer, # 5 Exhibit 4 to Declaration of Clayton Cramer, # 6 Supplemental Request for Judicial Notice In Support of Plaintiffs' Motion for Preliminary Injunction, # 7 Exhibit L to Supplemental RJN -Florida Department of Agriculture and Consumer Services Acceptable Firearms Training Documentation Webpage., # 8 Exhibit M to Supplemental RJN - Florida Department of Agriculture and Consumer Services Eligibility Requirements for a Florida Concealed Weapon License Webpage, # 9 Exhibit N to Supplemental RJN - Riverside County Sheriffs Department Concealed Carry License Webpage, Permitium, # 10 Exhibit O to Supplemental RJN - San Bernardino County Sheriffs Department Concealed Carry License Webpage, Permitium, # 11 Evidentiary Objections to Defendant Los Angeles County Sheriff's Department's and Sheriff Robert Luna's Survey of Historical License Requirements and Motion to Strike of Deny Same, # 12 Evidentiary Objection and Motion to Strike Declaration of Professor Brennan Rivas in Support of Defendant Robert Bonta's Opposition to Plaintiffs' Motion for Preliminary Injunction, # 13 Evidentiary Objection and Motion to Strike Declaration of Professor Robert Spitzer in Support of Defendant Robert Bonta's Opposition to Plaintiffs' Motion for Preliminary Injunction, # 14 Evidentiary Objection and Motion to Strike Declaration of Professor Michael Vorenberg in Support of Defendant Robert Bonta's Opposition to Plaintiffs' Motion for Preliminary Injunction)(Michel, Carl) (Entered: 02/28/2024)

1 Declaration of Clayton Cramer in Support of Plaintiffs' Motion for Prelimin

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2 Exhibit 1 to Declaration of Clayton Cramer

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3 Exhibit 2 to Declaration of Clayton Cramer

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4 Exhibit 3 to Declaration of Clayton Cramer

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5 Exhibit 4 to Declaration of Clayton Cramer

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6 Supplemental Request for Judicial Notice In Support of Plaintiffs' Motion

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7 Exhibit L to Supplemental RJN -Florida Department of Agriculture and Consumer Se

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8 Exhibit M to Supplemental RJN - Florida Department of Agriculture and Consumer S

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9 Exhibit N to Supplemental RJN - Riverside County Sheriffs Department Concealed C

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10 Exhibit O to Supplemental RJN - San Bernardino County Sheriffs Department Concea

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11 Evidentiary Objections to Defendant Los Angeles County Sheriff's Departmen

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12 Evidentiary Objection and Motion to Strike Declaration of Professor Brennan Riv

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13 Evidentiary Objection and Motion to Strike Declaration of Professor Robert Spit

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14 Evidentiary Objection and Motion to Strike Declaration of Professor Michael Vor

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ORDER by Judge Sherilyn Peace Garnett: Granting Application of Non-Resident Attorney Ryan Chabot to Appear Pro Hac Vice on behalf of Defendant Los Angeles County Sheriff's Dept and Sheriff Robert Luna, designating Henry Nikogosyan as local counsel 31 . (iv) (Entered: 02/29/2024)

SUPPLEMENTAL OBJECTIONS TO PLAINTIFFS' EVIDENCE SUBMITTED IN SUPPORT OF re: NOTICE OF MOTION AND MOTION for Preliminary Injunction 20 filed by Defendants Colleen Flores, La Verne Police Department. (Lindsay, Bruce) (Entered: 03/04/2024)

Text Only Scheduling Notice

SCHEDULING NOTICE AND ORDER by Judge Sherilyn Peace Garnett. On the Courts own motion, PLAINTIFFS MOTION FOR PRELIMINARY INJUCTION filed at ECF No. 20 set for hearing March 13, 2024, is CONTINUED to April 10, 2024 at 1:30 p.m. THERE IS NO PDF DOCUMENT ASSOCIATED WITH THIS ENTRY. (pg) TEXT ONLY ENTRY (Entered: 03/04/2024)

OPPOSITION filed by Defendant Robert Bonta. (Lopez, Christina) (Entered: 03/05/2024)

OBJECTIONS to Rebuttal Declaration of Clayton Cramer filed by Defendant Robert Bonta. (Lopez, Christina) (Entered: 03/05/2024)

RESPONSE filed by Defendants Los Angeles County Sheriffs Department, Robert Lunato Reply (Motion related),,,,,,,, 32 to Evidentiary Objections to Defendant Los Angeles County Sheriff's Department's and Sheriff Robert Luna's Survey of Historical License Requirements and Motion to Strike of Deny Same (Selwyn, Mark) (Entered: 03/20/2024)

(TEXT ENTRY) MINUTES RE PLAINTIFFS MOTION FOR PRELIMINARY INJUNCTION 20 held before Judge Sherilyn Peace Garnett. Arguments by counsel are heard. The Court reserves taking the motion under submission pending further questions by the Court. Court Reporter: Miranda Algorri. Attorneys present for plaintiff. Joshua Dale. Konstadinos Moros. Attorneys present for defendant. Mark Selwyn. Ryan Chabot, Bruce Lindsay, Christina Lopez, and Jane Reilley.Courtroom Deputy: Patricia Gomez. Time in Court: 1.42. (pg) (Entered: 04/10/2024)

Motion Hearing

TRANSCRIPT ORDER as to Defendants Los Angeles County Sheriffs Department, Robert Luna for Court Reporter. Court will contact Mariana P. Rocha at mariana.rocha@wilmerhale.com with further instructions regarding this order. Transcript preparation will not begin until payment has been satisfied with the court reporter. (Chabot, Ryan) (Entered: 04/11/2024)

TRANSCRIPT ORDER as to Plaintiffs California Rifle and Pistol Association, Incorporated, Cynthia Gabaldon, Gun Owners Foundation, Gun Owners of America, Inc., Gun Owners of California, Inc., Stephen Hoover, Charles Messel, Keith Reeves, Clarence Rigali, The Second Amendment Foundation, Erick Velasquez, Brian Weimer for Court Reporter. Court will contact Christina Castron at ccastron@michellawyers.com with further instructions regarding this order. Transcript preparation will not begin until payment has been satisfied with the court reporter. (Dale, Joshua) (Entered: 04/11/2024)

TRANSCRIPT ORDER as to Defendant Robert Bonta for Court Reporter. Court will contact Christina Lopez at christina.lopez@doj.ca.gov with further instructions regarding this order. Transcript preparation will not begin until payment has been satisfied with the court reporter. (Lopez, Christina) (Entered: 04/11/2024)

REQUEST FOR JUDICIAL NOTICE re NOTICE OF MOTION AND MOTION for Preliminary Injunction 20 (Supplemental) filed by Plaintiffs Gun Owners Foundation, Gun Owners of America, Inc., Gun Owners of California, Inc., Stephen Hoover, Charles Messel, Keith Reeves, Clarence Rigali, The Second Amendment Foundation, Erick Velasquez, Brian Weimer. (Attachments: # 1 Exhibit P - Brief of the United States, United States of America v. David Robinson, Jr., No. 23-12551 (11th Cir. Mar. 29, 2024))(Michel, Carl) (Entered: 04/26/2024)

1 Exhibit P - Brief of the United States, United States of America v. David Robins

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OPPOSITION to Plaintiff's Supplemental Request for Judicial Notice [DOC 43] In Support of re: NOTICE OF MOTION AND MOTION for Preliminary Injunction 20 filed by Defendants Colleen Flores, La Verne Police Department. (Lindsay, Bruce) (Entered: 05/02/2024)

SUPPLEMENT to NOTICE OF MOTION AND MOTION for Preliminary Injunction 20 filed by Plaintiffs California Rifle and Pistol Association, Incorporated, Cynthia Gabaldon, Gun Owners Foundation, Gun Owners of America, Inc., Gun Owners of California, Inc., Stephen Hoover, Charles Messel, Keith Reeves, Clarence Rigali, The Second Amendment Foundation, Erick Velasquez, Brian Weimer. (Attachments: # 1 Exhibit A-Ruling in the matter of United States v. Duarte, No. 22-50048, 2024 WL 2068016 (9th Cir. May 9, 2024)., # 2 Exhibit B-Signed Stipulated Judgment and Stipulated Permanent Injunction)(Michel, Carl) (Entered: 05/10/2024)

1 Exhibit A-Ruling in the matter of United States v. Duarte, No. 22-50048, 2024 WL

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2 Exhibit B-Signed Stipulated Judgment and Stipulated Permanent Injunction

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RESPONSE filed by Defendants Los Angeles County Sheriffs Department, Robert Lunato Supplement(Motion related),, 45 (Chabot, Ryan) (Entered: 05/17/2024)

JOINDER filed by Defendants Colleen Flores, La Verne Police Department joining in Response 46 . (Lindsay, Bruce) (Entered: 05/20/2024)

REQUEST FOR JUDICIAL NOTICE (Supplemental) In Support of La Verne Defendants' Opposition to Plaintiffs' Motion for Preliminary Injunction filed by Defendants Colleen Flores, La Verne Police Department. (Attachments: # 1 Declaration Lt. Chris Dransfeldt, # 2 Declaration Bruce A. Lindsay)(Lindsay, Bruce) (Entered: 05/23/2024)

1 Declaration Lt. Chris Dransfeldt

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2 Declaration Bruce A. Lindsay

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Notice RE SUPPLEMENTAL DECLARATION OF LT. CHRIS DRANSFELDT [ECF No. 48-1] IN SUPPORT OF DEFENDANTS CITY OF LA VERNE AND LA VERNE CHIEF OF POLICE COLLEEN FLORES OPPOSITION TO PLAINTIFFS MOTION FOR PRELIMINARY INJUNCTION filed by Defendants Colleen Flores, La Verne Police Department. (Lindsay, Bruce) (Entered: 05/24/2024)

OBJECTIONS to Request for Judicial Notice, 48 (Partial) filed by Plaintiffs California Rifle and Pistol Association, Incorporated, Cynthia Gabaldon, Gun Owners Foundation, Gun Owners of America, Inc., Gun Owners of California, Inc., Stephen Hoover, Charles Messel, Keith Reeves, Clarence Rigali, The Second Amendment Foundation, Erick Velasquez, Brian Weimer. (Michel, Carl) (Entered: 05/24/2024)

SUPPLEMENT to NOTICE OF MOTION AND MOTION for Preliminary Injunction 20 Notice of Supplemental Authority filed by Plaintiffs California Rifle and Pistol Association, Incorporated, Cynthia Gabaldon, Gun Owners Foundation, Gun Owners of America, Inc., Gun Owners of California, Inc., Stephen Hoover, Charles Messel, Keith Reeves, Clarence Rigali, Erick Velasquez, Brian Weimer. (Michel, Carl) (Entered: 07/29/2024)

ORDER GRANTING IN PART, DENYING IN PART, PLAINTIFFS' MOTION FOR PRELIMINARY INJUNCTION [ECF NO. 20] by Judge Sherilyn Peace Garnett Granting in part and Denying in part 20 MOTION for Preliminary Injunction: For the foregoing reasons, the Court GRANTS, in part, and DENIES, in part, Plaintiffs' Motion for a preliminary injunction. The Court further ORDERS: (1) Within twenty-one (21) calendar days of the date this Order is entered on the docket, Defendants must file their response to the Complaint pursuant to the Court's December 26, 2023, Order on the parties' stipulation to extend each Defendants' time to answer the Complaint, see (ECF No. 17); and (2) Within thirty (30) calendar days of this Order being entered on the docket, Plaintiffs must meet and confer with the State and the LA Defendants to submit a proposed order entering the preliminary injunction consistent with the specific findings made in this Order. (see document for further details) (bm) (Entered: 08/20/2024)

STIPULATION for Leave to File First Amended and Supplemental Complaint filed by Plaintiffs California Rifle and Pistol Association, Incorporated, Cynthia Gabaldon, Gun Owners Foundation, Gun Owners of America, Inc., Gun Owners of California, Inc., Stephen Hoover, Charles Messel, Keith Reeves, Clarence Rigali, The Second Amendment Foundation, Erick Velasquez, Brian Weimer. (Attachments: # 1 Proposed Order)(Attorney Konstadinos T. Moros added to party The Second Amendment Foundation(pty:pla))(Moros, Konstadinos) (Entered: 09/05/2024)

ORDER GRANTING PLAINTIFFS LEAVE TO FILE FIRST AMENDED AND SUPPLEMENTAL COMPLAINT 53 by Judge Sherilyn Peace Garnett. Plaintiffs shall file their First Amended and Supplemental Complaint, which is attached as Exhibit B to the Parties' stipulation within three (3) calendar days of this order. (iv) (Entered: 09/10/2024)

FIRST AMENDED COMPLAINT against DEFENDANT All Defendants amending Complaint (Attorney Civil Case Opening),,,, 1, filed by Plaintiff Cynthia Gabaldon, Charles Messel, The Second Amendment Foundation, California Rifle and Pistol Association, Incorporated, Erick Velasquez, Gun Owners of America, Inc., Clarence Rigali, Stephen Hoover, Brian Weimer, Gun Owners Foundation, Keith Reeves, Gun Owners of California, Inc.(Attorney Carl Dawson Michel added to party The Second Amendment Foundation(pty:pla))(Michel, Carl) (Entered: 09/13/2024)

Notice Joint Statement re Proposed Preliminary Injunction Order filed by Defendant Robert Bonta. (Lopez, Christina) (Entered: 09/19/2024)

Notice filed by PLAINTIFF Keith Reeves, Cynthia Gabaldon, California Rifle and Pistol Association, Incorporated, The Second Amendment Foundation, Gun Owners of America, Inc., Gun Owners Foundation, Gun Owners of California, Inc., Erick Velasquez, Charles Messel, Brian Weimer, Clarence Rigali. [PROPOSED] ORDER ENTERING PRELIMINARY INJUNCTION (Michel, Carl) (Entered: 09/23/2024)

ANSWER to Amended Complaint/Petition,, 55 filed by Defendants La Verne Police Department, Colleen Flores.(Lindsay, Bruce) (Entered: 10/15/2024)

ANSWER to Amended Complaint/Petition,, 55 filed by Defendant Robert Bonta.(Lopez, Christina) (Entered: 10/28/2024)

NOTICE OF MOTION AND MOTION to Dismiss Plaintiffs' First Amended and Supplemental Complaint filed by Defendants Los Angeles County Sheriffs Department, Robert Luna. Motion set for hearing on 1/15/2025 at 01:30 PM before Judge Sherilyn Peace Garnett. (Attachments: # 1 Proposed Order) (Selwyn, Mark) (Entered: 10/28/2024)

STIPULATION for Order Regarding Briefing Schedule for Defendants Los Angeles County Sheriff's Department and Sheriff Robert Luna's Motion to Dismiss Plaintiffs' First Amended and Supplemental Complaint filed by Defendant Los Angeles County Sheriffs Department, Robert Luna. (Attachments: # 1 Proposed Order)(Chabot, Ryan) (Entered: 10/28/2024)

ORDER SETTING SCHEDULING CONFERENCE by Judge Sherilyn Peace Garnett. Rule 26 Meeting Report due by 11/13/2024. Scheduling Conference set for 11/27/2024 at 03:00 PM before Judge Sherilyn Peace Garnett. (pg) (Entered: 10/29/2024)

ORDER GRANTING STIPULATION TO SET BRIEFING SCHEDULE FOR DEFENDANTS LOS ANGELES COUNTY SHERIFF'S DEPARTMENT AND SHERIFF ROBERT LUNA'S MOTION TO DISMISS PLAINTIFFS'FIRST AMENDED AND SUPPLEMENTAL COMPLAINT 61 by Judge Sherilyn Peace Garnett. The deadline for filing Plaintiffs' response to the Motion to Dismiss is December 2, 2024. The deadline for filing Defendants' Los Angeles County Sheriff's Department and Sheriff Robert Luna's Reply, if any, is December 23, 2024. (iv) (Entered: 10/29/2024)

Notice of Appearance or Withdrawal of Counsel: for attorney Joshua A Vittor counsel for Defendants Los Angeles County Sheriffs Department, Robert Luna. Adding Joshua A. Vittor as counsel of record for Los Angeles County Sheriff's Department and Sheriff Robert Luna for the reason indicated in the G-123 Notice. Filed by Defendant Los Angeles County Sheriff's Department and Sheriff Robert Luna. (Attorney Joshua A Vittor added to party Los Angeles County Sheriffs Department(pty:dft), Attorney Joshua A Vittor added to party Robert Luna(pty:dft))(Vittor, Joshua) (Entered: 11/12/2024)

Notice of Appearance or Withdrawal of Counsel: for attorney Henry Michael Nikogosyan counsel for Defendants Los Angeles County Sheriffs Department, Robert Luna. Henry Michael Nikogosyan is no longer counsel of record for the aforementioned party in this case for the reason indicated in the G-123 Notice. Filed by Defendant Los Angeles County Sheriff's Department and Sheriff Robert Luna. (Nikogosyan, Henry) (Entered: 11/12/2024)

NOTICE of Appearance filed by attorney Nicholas Reiss Green on behalf of Defendant Robert Bonta (Attorney Nicholas Reiss Green added to party Robert Bonta(pty:dft))(Green, Nicholas) (Entered: 11/12/2024)

JOINT FED. R. CIV. P. 26(f) REPORT filed by Plaintiffs Keith Reeves, Cynthia Gabaldon, Stephen Hoover, California Rifle and Pistol Association, Incorporated, The Second Amendment Foundation, Gun Owners of America, Inc., Gun Owners Foundation, Gun Owners of California, Inc., Erick Velasquez, Charles Messel, Brian Weimer, Clarence Rigali. (Attachments: # 1 Schedule of Pretrial and Trial Dates Worksheet)(Moros, Konstadinos) (Entered: 11/13/2024)

1 Schedule of Pretrial and Trial Dates Worksheet

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STIPULATION to Vacate November 27, 2024 Scheduling Conference Report, 67, Initial Order Setting R26 Scheduling Conference - form only 62, STIPULATION to Continue November 27, 2024 Scheduling Conference from November 27, 2024 Re: Report, 67, Initial Order Setting R26 Scheduling Conference - form only 62 filed by Defendant Robert Bonta. (Attachments: # 1 Proposed Order Proposed Order)(Lopez, Christina) (Entered: 11/18/2024)

1 Proposed Order Proposed Order

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ORDER/REFERRAL to ADR Procedure No 1 by Judge Sherilyn Peace Garnett. Case ordered to Magistrate Judge assigned to the case for Settlement Conference. ADR Proceeding to be held no later than 9/24/2025. (iv) (Entered: 11/20/2024)

STANDING ORDER FOR MOTIONS FOR SUMMARY JUDGMENT by Judge Sherilyn Peace Garnett. READ THIS ORDER CAREFULLY. IT CONTROLS THIS CASE AND DIFFERS IN SOME RESPECTS FROM THE LOCAL RULES. (iv) (Entered: 11/20/2024)

CIVIL PRETRIAL SCHEDULE AND TRIAL ORDER by Judge Sherilyn Peace Garnett. Final Pretrial Conference set for 10/29/2025 at 3:00 PM before Judge Sherilyn Peace Garnett. Court Trial set for 11/17/2025 at 8:30 AM before Judge Sherilyn Peace Garnett. SEE ORDER FOR DETAILS. (Attachments: # 1 Schedule of Pretrial and Trial Dates Worksheet) (iv) (Entered: 11/21/2024)

1 Schedule of Pretrial and Trial Dates Worksheet

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TEXT ONLY ENTRY: This matter has been referred to Magistrate Judge Autumn D. Spaeth for settlement conference proceedings 69 . For Judge Spaeth's settlement conference procedures, the parties are referred to her procedures page of the Court's website, http://www.cacd.uscourts.gov/honorable-autumn-d-spaeth. THERE IS NO PDF DOCUMENT ASSOCIATED WITH THIS ENTRY. (kh) TEXT ONLY ENTRY (Entered: 11/21/2024)

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(IN CHAMBERS) ORDER by Judge Sherilyn Peace Garnett: The Court has reviewed the Joint Rule 26(f) Report submitted by the parties and determines that an in-person Scheduling Conference is unnecessary. Accordingly, the Court VACATES the November 27, 2024, Scheduling Conference. Trial Orders issued, see ECF Nos. 69,70, and 72. THERE IS NO PDF DOCUMENT ASSOCIATED WITH THIS ENTRY. (pg) TEXT ONLY ENTRY (Entered: 11/22/2024)

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MEMORANDUM in Opposition to NOTICE OF MOTION AND MOTION to Dismiss Plaintiffs' First Amended and Supplemental Complaint 60 filed by Plaintiffs Keith Reeves, Cynthia Gabaldon, Stephen Hoover, California Rifle and Pistol Association, Incorporated, Gun Owners of America, Inc., Gun Owners Foundation, Gun Owners of California, Inc., Erick Velasquez, Charles Messel, Brian Weimer, Clarence Rigali. (Michel, Carl) (Entered: 12/02/2024)

NOTICE OF REASSIGNMENT of California Attorney General Office Nicholas R. Green on behalf of Defendant Robert Bonta. California Attorney General Christina Rae Burgart Lopez terminated. (Lopez, Christina) (Entered: 12/17/2024)

SCHEDULING NOTICE and ORDER by Judge Sherilyn Peace Garnett. The Court, on its own motion, continues the hearing from January 15, 2025, to January 22, 2025, at 1:30 p.m. for Defendants' Motion to Dismiss Plaintiffs' First Amended and Supplemental Complaint (ECF No. 60 ("Motion")). However, the Court's continuance of the hearing for this Motion neither extends nor modifies the briefing schedule for the parties to file any opposition and reply. Accordingly, under the Local Rules 7-9 and 7-10, any opposition to the Motion shall be due twenty-one (21) days before January 15, 2025, and any reply shall be due fourteen (14) days before January 15, 2025. IT IS SO ORDERED. THERE IS NO PDF DOCUMENT ASSOCIATED WITH THIS ENTRY. (rs) TEXT ONLY ENTRY (Entered: 12/23/2024)

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REPLY IN SUPPORT OF NOTICE OF MOTION AND MOTION to Dismiss Plaintiffs' First Amended and Supplemental Complaint 60 filed by Defendants Los Angeles County Sheriffs Department, Robert Luna. (Selwyn, Mark) (Entered: 12/23/2024)

APPLICATION of Non-Resident Attorney Todd A. Clayton to Appear Pro Hac Vice on behalf of Defendants Los Angeles County Sheriffs Department, Robert Luna (Pro Hac Vice Fee - $500 Fee Paid, Receipt No. ACACDC-38877682) filed by Defendants Los Angeles County Sheriffs Department, Robert Luna. (Attachments: # 1 Proposed Order) (Vittor, Joshua) (Entered: 01/08/2025)

1 Proposed Order

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ORDER by Judge Sherilyn Peace Garnett: granting 78 Non-Resident Attorney Todd A Clayton APPLICATION to Appear Pro Hac Vice on behalf of defendants Los Angeles County Sheriffs Department,Robert Luna, designating Joshua Vittor as local counsel. THERE IS NO PDF DOCUMENT ASSOCIATED WITH THIS ENTRY (ak) (Entered: 01/09/2025)

Appear Pro Hac Vice

SCHEDULING NOTICE AND ORDER by Judge Sherilyn Peace Garnett. The MOTION TO DISMISS PLAINTIFFS FIRST AMENDED AND SUPPLEMENTAL COMPLAINT 60 set for hearing January 22, 2025, is taken off calendar. No appearance necessary. THERE IS NO PDF DOCUMENT ASSOCIATED WITH THIS ENTRY. (pg) TEXT ONLY ENTRY (Entered: 01/14/2025)

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ORDER ENTERING PRELIMINARY INJUNCTION by Judge Sherilyn Peace Garnett. The Court, having reviewed the Proposed Order, accordingly ORDERS, as to Defendant Bonta and as to the Los Angeles County Defendants. The California Department of Justice shall distribute a copy of this Order, or otherwise provide notice of its terms, to all Local Issuing Authorities that currently issue or shall issue in the future concealed handgun licenses in California and to all District Attorney offices.The deadlines of this Order may be modified by stipulation of the parties for good cause, including any delay that is caused by Plaintiff Weimer not timely completing the actions required of him to obtain his license, such as completing the livescan and the training course. [See Order for further details.] (san) (Entered: 01/23/2025)

Notice of Appearance or Withdrawal of Counsel: for attorney Anna M Barvir counsel for Plaintiffs Keith Reeves, Cynthia Gabaldon, Stephen Hoover, California Rifle and Pistol Association, Incorporated, Gun Owners of America, Inc., Gun Owners Foundation, Gun Owners of California, Inc., Erick Velasquez, Charles Messel, Brian Weimer, Clarence Rigali. Filed by Plaintiffs California Rifle & Pistol Association, Inc., Gun Owners of America, Inc., Gun Owners Foundation, Gun Owners of California, Inc., Erick Velasquez, Charles Messel, Brian Weimer, Clarence Rigali, Keith Reeves, Cynthia Gabaldon, and Stephen Hoover. (Attorney Anna M Barvir added to party Keith Reeves(pty:pla), Attorney Anna M Barvir added to party Cynthia Gabaldon(pty:pla), Attorney Anna M Barvir added to party Stephen Hoover(pty:pla), Attorney Anna M Barvir added to party California Rifle and Pistol Association, Incorporated (pty:pla), Attorney Anna M Barvir added to party Gun Owners of America, Inc.(pty:pla), Attorney Anna M Barvir added to party Gun Owners Foundation(pty:pla), Attorney Anna M Barvir added to party Gun Owners of California, Inc.(pty:pla), Attorney Anna M Barvir added to party Erick Velasquez(pty:pla), Attorney Anna M Barvir added to party Charles Messel(pty:pla), Attorney Anna M Barvir added to party Brian Weimer(pty:pla), Attorney Anna M Barvir added to party Clarence Rigali(pty:pla))(Barvir, Anna) (Entered: 01/29/2025)

Notice of Appearance or Withdrawal of Counsel: for attorney Todd A Clayton counsel for Defendants Los Angeles County Sheriffs Department, Robert Luna. Todd A. Clayton is no longer counsel of record for the aforementioned party in this case for the reason indicated in the G-123 Notice. Filed by Defendant Los Angeles County Sheriff's Department and Sheriff Robert Luna. (Clayton, Todd) (Entered: 02/20/2025)

Notice of Appearance or Withdrawal of Counsel: for attorney Kimberly Hall Barlow counsel for Defendant La Verne Police Department. Monica Choi Arredondo is no longer counsel of record for the aforementioned party in this case for the reason indicated in the G-123 Notice. Filed by Defendant La Verne Police Department. (Attorney Kimberly Hall Barlow added to party La Verne Police Department(pty:dft))(Barlow, Kimberly) (Entered: 03/04/2025)

NOTICE TO FILER OF DEFICIENCIES in Electronic Filed Document RE: Notice of Appearance or Withdrawal of Counsel (G-123), 84 . The following error(s) was/were found: Incomplete Section I; missing name of party In response to this notice, the Court may: (1) order an amended or correct document to be filed; (2) order the document stricken; or (3) take other action as the Court deems appropriate. You need not take any action in response to this notice unless and until the Court directs you to do so. (ak) (Entered: 03/06/2025)

Notice of Appearance or Withdrawal of Counsel: for attorney Kimberly Hall Barlow counsel for Defendants La Verne Police Department, Colleen Flores. Monica Choi Arredondo is no longer counsel of record for the aforementioned party in this case for the reason indicated in the G-123 Notice. Filed by Defendants La Verne Police Department. (Attorney Kimberly Hall Barlow added to party Colleen Flores(pty:dft))(Barlow, Kimberly) (Entered: 03/07/2025)

Notice of Appearance or Withdrawal of Counsel: for attorney Kimberly Hall Barlow counsel for Defendants La Verne Police Department, Colleen Flores. Bruce A. Lindsay is no longer counsel of record for the aforementioned party in this case for the reason indicated in the G-123 Notice. Filed by Defendants La Verne Police Department. (Barlow, Kimberly) (Entered: 03/07/2025)

Joint STIPULATION for Order Requesting Extension of Case Deadlines filed by Defendants Los Angeles County Sheriffs Department, Robert Luna. (Attachments: # 1 Proposed Order)(Chabot, Ryan) (Entered: 03/13/2025)

1 Proposed Order

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ORDER GRANTING IN PART AND DENYING IN PART JOINT STIPULATED REQUEST FOR EXTENSION OF CASE DEADLINES 60 by Judge Sherilyn Peace Garnett. The date for Final Pretrial Conference is extended to January 7, 2026 at 11:00 a.m. and the date for Trial is extended to January 27, 2026. (iv) (Entered: 03/14/2025)

NOTICE of Appearance filed by attorney Robert William Setrakian on behalf of Defendant Robert Bonta (Attorney Robert William Setrakian added to party Robert Bonta(pty:dft))(Setrakian, Robert William) (Entered: 04/17/2025)

(IN CHAMBERS) ORDER SETTING PRE-SETTLEMENT CONFERENCE CALL by Magistrate Judge Autumn D. Spaeth. This matter is set for a Pre-Settlement Conference Call on May 29, 2025 at 2:00 p.m. Call information shall be provided by separate email. THERE IS NO PDF DOCUMENT ASSOCIATED WITH THIS ENTRY. (kh) TEXT ONLY ENTRY (Entered: 05/22/2025)

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ORDER RE: SETTLEMENT CONFERENCE by Magistrate Judge Autumn D. Spaeth: The Settlement Conference is placed on calendar for June 24, 2025, at 10:00 a.m., in Courtroom 6B, 6th Floor, 411 W. Fourth Street, Santa Ana, California, 92701. No later than five (5) days prior to the Settlement Conference, each party shall submit a Confidential Settlement Conference Statement directly to the Chambers of Judge Spaeth via email to ADS_Chambers@cacd.uscourts.gov. The Statements should not be filed with the Clerk of the Court and they will not be made part of the casefile. **See Order for details** (kh) (Entered: 05/22/2025)