California Rifle and Pistol Association, Incorporated v. Los Angeles County Sheriffs Department (2:23-cv-10169)

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)

(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)

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)

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)

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)

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)

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)

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)

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)

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

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

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)

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)

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)

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)

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

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)

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)

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)

(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)

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

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)

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)

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)

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

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)

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)

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)

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)

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)

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)

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)

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 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)

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)

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

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

NOTICE of Interested Parties filed by Plaintiffs All Plaintiffs, (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)