`
`nN&Wwbd
`OoCO“SN
`
`13
`
`14
`
`15
`
`16
`17
`
`19
`
`20
`
`Attorneys for Defendants County of
`Siskiyou; Jeremiah LaRue and Jesus
`Fernandez,in their official capacities
`as members of the Siskiyou County
`Sheriff's Department and in their individual
`capacities; Brandon Criss, Ed Valenzuela,
`Michael N. Kobseff, Nancy Ogren, and
`Ray A. Haupt, in their official capacities
`||as members of the Siskiyou County Board
`of Supervisors andin their individual
`11||capacities; Edward Kiernan,in his official
`capacity as County Counsel for Siskiyou
`12|County andin his individual capacity;
`and DOES 1-100
`
`10
`
`UNITED STATES DISTRICT COURT
`
`FOR THE EASTERN DISTRICT OF CALIFORNIA
`
`SACRAMENTODIVISION
`Vang, Nathan Thao, Mao.
`Dilevon Lo, Jerry
`Thao, Pao Lee, Antonio Lee, Koua Lee, Nhia
`Thai Vang, Zeng Lee, Der Lee and Khue Cha,
`
`Case No. 2:21-cv-00999-KJM-DMC
`
`DEFENDANTS’ NOTICE OF MOTION
`AND MOTIONFOR DISSOLUTION OF
`THE COURT’S ORDER GRANTING A
`PARTIAL PRELIMINARY INJUNCTION
`
`Plaintiffs,
`
`VS.
`
`Case 2:21-cv-00999-KJM-AC Document 57 Filed 02/18/22 Page 1 of 2
`Case 2:21-cv-00999-KJM-AC Document 57 Filed 02/18/22 Page 1 of 2
`
`SPINELLI, DONALD & NOTT
`A Professional Corporation
`DOMENIC D. SPINELLI (SBN: 131192)
`J. SCOTT DONALD(SBN: 158338)
`JEFFREY C. CHIAO (SBN: 236781)
`601 University Avenue, Suite 225
`Sacramento, CA 95825
`Telephone: (916) 448-7888
`Facsimile:
`(916) 448-6888
`
`Complaint Filed: June 4, 2021
`21|County of Siskiyou; Jeremiah LaRue and
`First Amended Complaint Filed: July 15, 2021
`Jesus Fernandez, in their official capacities as
`32||members of the Siskiyou County Sheriff's
`Date: March 25, 2022
`Departmentand in their individual capacities;
`93|an BrandonCriss, Ed Valenzuela, Michael N.
`Time: 10:00 AM
`Courtroom: 3, 15" Floor
`Kobseff, Nancy Ogren, and Ray A. Haupt, in
`A their official capacities as membersof the
`Siskiyou County Board of Supervisors and in
`Judge: Hon. Kimberly J. Mueller
`their individual capacities; Edward Kiernan, in
`25||his official capacity as County Counsel for
`Siskiyou County and in his individual
`[FEES EXEMPT PURSUANT TO
`26||capacity; and DOES 1-100,
`GOVERNMENTCODE SECTION 6103]
`
`
`
`Defendants.
`
`
`SPINELLI, DONALC
`& NOTT
`
`1
`DEFENDANTS’ NOTICE OF MOTION AND MOTION FOR DISSOLUTION OF THE COURT’S ORDER
`GRANTING A PARTIAL PRELIMINARY INJUNCTION
`
`
`
`Case 2:21-cv-00999-KJM-AC Document 57 Filed 02/18/22 Page 2 of 2
`Case 2:21-cv-00999-KJM-AC Document 57 Filed 02/18/22 Page 2 of 2
`
`NOTICE IS HEREBY GIVENthat on March 25, 2022 at 10:00 a.m., in the Courtroom of
`
`the Honorable Kimberly J. Mueller, Courtroom 3, 15" Floor, located at 501 I Street, Sacramento,
`
`California, 95814, Defendants County of Siskiyou; Jeremiah LaRue and Jesus Fernandez, in their
`
`official capacities as membersof the Siskiyou County Sheriffs Department andin their individual
`
`capacities; Brandon Criss, Ed Valenzuela, Michael N. Kobseff, Nancy Ogren, and Ray A. Haupt, in
`
`their official capacities as members of the Siskiyou County Board of Supervisors andin their
`
`individual capacities; Edward Kiernan,in his official capacity as County Counsel for Siskiyou
`
`County andin his individual capacity, will and do file a Motion for Dissolution of The Court’s Order
`
`
`
`
`
`_WwW
`
`OoCOSSDBDAN
`
`24
`
`25
`
`26
`
`27
`
`28
`
`Granting a Partial Preliminary Injunction.
`
`This Motion will be based upon this Notice; the Memorandum of Points and Authorities in
`
`support hereof; the Affidavits of Jeremiah LaRue, Rick Dean and Ray A. Haupt, andall records and
`
`documentsonfile herein, and such other and further evidence or matters as may be presented or
`
`offered here, in the reply brief and at the time of the hearing on this Motion.
`
`Dated: February 18, 2022
`
`SPINELLI, DONALD & NOTT
`
`By
`
`/s/ J. Scott Donald
`J. SCOTT DONALD
`Attorneys for Defendants
`COUNTY OF SISKIYOU
`
`CERTIFICATION OF MEET AND CONFER EFFORTS
`
`Counsel for Defendants met and conferred with counsel for Plaintiffs through written
`
`correspondence on February 9, 2022, February 12, 2022, and February 16; and a telephone
`
`conference on February 17, 2022 regarding the issues raised in this motion. Asofthe filing ofthis
`
`motion,the parties had not come to an agreement with respect to the issues raised in this motion.
`
`Dated: February 18, 2022
`
`SPINELLI, DONALD & NOTT
`
`By
`
`___/s/ J. Scott Donald
`J. SCOTT DONALD
`Attorneys for Defendants
`COUNTYOFSISKIYOU
`
`SPINELLI, DONALC
`& NOTT
`
`2
`DEFENDANTS’ NOTICE OF MOTION AND MOTION FOR DISSOLUTION OF THE COURT’S ORDER
`GRANTING A PARTIAL PRELIMINARY INJUNCTION
`
`