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Defendants' Notice of Intent To Oppose Plaintiff'S Motion For Temporary Restraining Order and Preliminary Injunction-1
Defendants' Notice of Intent To Oppose Plaintiff'S Motion For Temporary Restraining Order and Preliminary Injunction-1
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Honorable Thomas S. Zilly
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UNITED STATES DISTRICT COURT
WESTERN DISTRICT OF WASHINGTON AT SEATTLE
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MICHAEL LEAL,
Plaintiff,
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v.
EVERETT PUBLIC SCHOOLS, GARY
COHN, in his individual and official
capacities as Superintendent of Everett
Public Schools, CATHY WOODS, in her
individual and official capacities as Principal
of Cascade High School, LAURA
PHILLIPS, in her individual and official
capacities as Assistant Principal of Cascade
High School, ROBERT AGUILAR, in his
individual and official capacities as
Assistant Principal of Cascade High School,
and DOES 1 THRU 100,
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Defendants.
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COME NOW Defendants Everett Public Schools, Gary Cohn, Cathy Woods, Laura
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Phillips, and Robert Aguilar, (Defendants), by and through their undersigned counsel, hereby
DEFENDANTS NOTICE OF INTENT TO OPPOSE
PLAINTIFFS MOTION FOR TEMPORARY
RESTRAINING ORDER AND PRELIMINARY
INJUNCTION- 1
2:14-cv-01762
372472.doc
PATTERS ON BU CHANAN
FOBES & LEI TCH, IN C., P.S.
2112 Third Avenue, Suite 500, Seattle WA 98121
Tel. 206.462.6700 Fax 206.462.6701
give notice of Defendants intent to respond in opposition to Plaintiffs Motion for Temporary
Pursuant to Fed. R. Civ. P. 65(b)(5), Defendants intend file their response within the
statutory timeframe on or about Monday, November 24, 2014, and respectfully request that the
Courts consideration of Plaintiffs motion be stayed until such time as Defendants have an
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By:
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DEFENDANTS NOTICE OF INTENT TO OPPOSE
PLAINTIFFS MOTION FOR TEMPORARY
RESTRAINING ORDER AND PRELIMINARY
INJUNCTION- 2
2:14-cv-01762
372472.doc
PATTERS ON BU CHANAN
FOBES & LEI TCH, IN C., P.S.
2112 Third Avenue, Suite 500, Seattle WA 98121
Tel. 206.462.6700 Fax 206.462.6701
CERTIFICATE OF SERVICE
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I, Theresa Nixon, hereby declare that on this 21st day of November, 2014, I electronically
filed the foregoing with the Clerk of the Court using the CM/ECF system which will send
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METHOD OF DELIVERY
Electronic Mail
ABC Legal Messenger Service
Regular U.S. Mail
Other: ________________________
Kevin T. Snider
Matthew B. McReynolds
Pacific Justice Institute
9751 HORN ROAD, SUITE 115
SACRAMENTO, CA 95827
ksnider@pji.org
mattmcreynolds@pji.org
I certify under penalty of perjury, under the laws of the State of Washington, that the
foregoing is true and correct.
DATED this 21st day of November, 2014 at Seattle, Washington.
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/s/Theresa Nixon_____
Theresa Nixon
Legal Assistant
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DEFENDANTS NOTICE OF INTENT TO OPPOSE
PLAINTIFFS MOTION FOR TEMPORARY
RESTRAINING ORDER AND PRELIMINARY
INJUNCTION- 3
2:14-cv-01762
372472.doc
PATTERS ON BU CHANAN
FOBES & LEI TCH, IN C., P.S.
2112 Third Avenue, Suite 500, Seattle WA 98121
Tel. 206.462.6700 Fax 206.462.6701