STIPULATION for Filing of Amended Complaint and (Proposed) Order filed by Jacob A Appelsmith, Edmund Brown, Jr, William Haraf, Kamala Harris, Traci Stevens, Robert Venchiarutti. (Southworth, Peter) (Filed on 1/23/2012) Modified on 1/24/2012 (bw, COURT STAFF).
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Page 1 Case5:11-cv-05496-HRL Document20 Filed01/23/12 Page1 of 3
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KAMALA D. HARRIS
Attorney General of California
PETER SOUTHWORTH
Supervising Deputy Attorney General
RYAN MARCROFT
Deputy Attorney General
State Bar No. 230952
1300 I Street, Suite 125
P.O. Box 944255
Sacramento, CA 94244-2550
Telephone: (916) 323-5313
Fax: (916) 324-8835
E-mail: Ryan.Marcroft@doj.ca.gov
Attorneys for All Defendants
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IN THE UNITED STATES DISTRICT COURT
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FOR THE NORTHERN DISTRICT OF CALIFORNIA
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SAN JOSE DIVISION
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Think Computer Corporation,
v.
5:11-cv-05496-HRL
Plaintiff, STIPULATION FOR FILING OF
AMENDED COMPLAINT AND
[PROPOSED] ORDER
Courtroom: 2
Judge:
The Honorable Howard R. Lloyd
Trial Date: Not Set
Action Filed: November 14, 2011
ROBERT VENCHIARUTTI, in his official
capacity as Deputy Commissioner of the
California Department of Financial
Institutions; WILLIAM HARAF, in his
official capacity as Commissioner of the
California Department of Financial
Institutions; TRACI STEVENS, in her
official capacity as Acting Secretary of the
California Business, Transportation and
Housing Agency; JACOB A.
APPELSMITH, in his official capacity as
Senior Advisor to the Governor of the State
of California; EDMUND G. BROWN, JR.,
in his official capacity as Governor of the
State of California; and KAMALA
HARRIS, in her official capacity as
Attorney General of the State of California,
Defendants.
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Stipulation for Filing Of Amended Complaint and [Proposed] Order (5:11-cv-05496-HRL)Page 2 Case5:11-cv-05496-HRL Document20 Filed01/23/12 Page2 of 3
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Plaintiff THINK COMPUTER CORPORATION and Defendants ROBERT
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VENCHIARUTTI, in his official capacity as Deputy Commissioner of the California Department
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of Financial Institutions, WILLIAM HARAF, in his official capacity as Commissioner of the
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California Department of Financial Institutions, TRACI STEVENS, in her official capacity as
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Acting Secretary of the California Business, Transportation and Housing Agency, JACOB A.
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APPELSMITH, in his official capacity as Senior Advisor to the Governor of the State of
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California, EDMUND G. BROWN, JR., in his official capacity as Governor of the State of
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California, and KAMALA HARRIS, in her official capacity as Attorney General of the State of
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California (collectively, the “State Defendants”), have met and conferred regarding the Complaint
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For Declaratory and Injunctive Relief and Jury Demand (Docket No. 1) and they HEREBY
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STIPULATE that Plaintiff will amend the complaint as a matter of course pursuant to Rule
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15(a)(1) of the Federal Rules of Civil Procedure and file the amended complaint no later than
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January 31, 2012. State Defendants will thereafter answer or otherwise respond to the amended
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complaint in accordance with Rule 15(a)(1).
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Dated: January 23, 2012
Respectfully submitted,
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KAMALA D. HARRIS
Attorney General of California
PETER SOUTHWORTH
Supervising Deputy Attorney General
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/s/ Peter Southworth
PETER SOUTHWORTH
Supervising Deputy Attorney General
Attorneys for Defendant
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/s/ Michael Brooks Carroll
MICHAEL BROOKS CARROLL, ESQ.
Law Offices of Michael Brooks Carroll
Attorneys for Plaintiff
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///
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///
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Stipulation for Filing Of Amended Complaint and [Proposed] Order (5:11-cv-05496-HRL)Page 3 Case5:11-cv-05496-HRL Document20 Filed01/23/12 Page3 of 3
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Pursuant to stipulation, so ordered.
Dated:
__________________________
Howard R. Lloyd
United States Magistrate Judge
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Stipulation for Filing Of Amended Complaint and [Proposed] Order (5:11-cv-05496-HRL)
PDF Page 1
PlainSite Cover Page
PDF Page 2
Case5:11-cv-05496-HRL Document20 Filed01/23/12 Page1 of 3
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KAMALA D. HARRIS
Attorney General of California
PETER SOUTHWORTH
Supervising Deputy Attorney General
RYAN MARCROFT
Deputy Attorney General
State Bar No. 230952
1300 I Street, Suite 125
P.O. Box 944255
Sacramento, CA 94244-2550
Telephone: (916) 323-5313
Fax: (916) 324-8835
E-mail: Ryan.Marcroft@doj.ca.gov
Attorneys for All Defendants
9
IN THE UNITED STATES DISTRICT COURT
10
FOR THE NORTHERN DISTRICT OF CALIFORNIA
11
SAN JOSE DIVISION
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
Think Computer Corporation,
v.
5:11-cv-05496-HRL
Plaintiff, STIPULATION FOR FILING OF
AMENDED COMPLAINT AND
[PROPOSED] ORDER
Courtroom: 2
Judge:
The Honorable Howard R. Lloyd
Trial Date: Not Set
Action Filed: November 14, 2011
ROBERT VENCHIARUTTI, in his official
capacity as Deputy Commissioner of the
California Department of Financial
Institutions; WILLIAM HARAF, in his
official capacity as Commissioner of the
California Department of Financial
Institutions; TRACI STEVENS, in her
official capacity as Acting Secretary of the
California Business, Transportation and
Housing Agency; JACOB A.
APPELSMITH, in his official capacity as
Senior Advisor to the Governor of the State
of California; EDMUND G. BROWN, JR.,
in his official capacity as Governor of the
State of California; and KAMALA
HARRIS, in her official capacity as
Attorney General of the State of California,
Defendants.
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Stipulation for Filing Of Amended Complaint and [Proposed] Order (5:11-cv-05496-HRL)
PDF Page 3
Case5:11-cv-05496-HRL Document20 Filed01/23/12 Page2 of 3
1
Plaintiff THINK COMPUTER CORPORATION and Defendants ROBERT
2
VENCHIARUTTI, in his official capacity as Deputy Commissioner of the California Department
3
of Financial Institutions, WILLIAM HARAF, in his official capacity as Commissioner of the
4
California Department of Financial Institutions, TRACI STEVENS, in her official capacity as
5
Acting Secretary of the California Business, Transportation and Housing Agency, JACOB A.
6
APPELSMITH, in his official capacity as Senior Advisor to the Governor of the State of
7
California, EDMUND G. BROWN, JR., in his official capacity as Governor of the State of
8
California, and KAMALA HARRIS, in her official capacity as Attorney General of the State of
9
California (collectively, the “State Defendants”), have met and conferred regarding the Complaint
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For Declaratory and Injunctive Relief and Jury Demand (Docket No. 1) and they HEREBY
11
STIPULATE that Plaintiff will amend the complaint as a matter of course pursuant to Rule
12
15(a)(1) of the Federal Rules of Civil Procedure and file the amended complaint no later than
13
January 31, 2012. State Defendants will thereafter answer or otherwise respond to the amended
14
complaint in accordance with Rule 15(a)(1).
15
Dated: January 23, 2012
Respectfully submitted,
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KAMALA D. HARRIS
Attorney General of California
PETER SOUTHWORTH
Supervising Deputy Attorney General
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/s/ Peter Southworth
PETER SOUTHWORTH
Supervising Deputy Attorney General
Attorneys for Defendant
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/s/ Michael Brooks Carroll
MICHAEL BROOKS CARROLL, ESQ.
Law Offices of Michael Brooks Carroll
Attorneys for Plaintiff
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///
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///
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Stipulation for Filing Of Amended Complaint and [Proposed] Order (5:11-cv-05496-HRL)
PDF Page 4
Case5:11-cv-05496-HRL Document20 Filed01/23/12 Page3 of 3
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Pursuant to stipulation, so ordered.
Dated:
__________________________
Howard R. Lloyd
United States Magistrate Judge
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Stipulation for Filing Of Amended Complaint and [Proposed] Order (5:11-cv-05496-HRL)
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