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STUART F. DELERY

Acting Assistant Attorney General, Civil Division

AUGUST FLENTJE

Acting Deputy Assistant Attorney General

DAVID J. KLINE

Director, Office of Immigration Litigation

JEFFREY S. ROBINS

Assistant Director

JESI J. CARLSON

Senior Litigation Counsel

LANA L. VAHAB (DC Bar No. 97620)

Trial Attorney

KATHERINE E.M. GOETTEL (IA Bar No. 23821)

Trial Attorney

Department of Justice, Civil DivisionOffice of Immigration Litigation

District Court Section

P.O. Box 868, Ben Franklin Station

Washington, DC 20044

Tel: (202) 532-4115

Email: [email protected]

Attorneys for Defendants

UNITED STATES DISTRICT COURT

FOR THE CENTRAL DISTRICT OF CALIFORNIA

WESTERN DIVISION

MARTIN ARANAS, et al., ) No. 12-cv-1137-CBM (AJWx)

)

Plaintiffs, ) DEFENDANTS OPPOSITION TO

) PLAINTIFFS EX PARTE

v. ) APPLICATION TO EXPEDITE

) HEARING AND RULING ON THEIRJANET NAPOLITANO, Secretary, ) MOTION TO COMPEL DISCOVERY

Department of Homeland Security, )

et al., ) Hon. Andrew J. Wistrich

Defendants. )

______________________________ ) U.S. Magistrate Judge

Case 8:12-cv-01137-CBM-AJW Document 61 Filed 10/18/12 Page 1 of 12 Page ID #:1355

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Defendants oppose Plaintiffs Ex Parte Application to Expedite a Hearing or

ruling on their Motion to Compel Discovery (Ex Parte Application) (See ECF

Nos. 59 & 60). The urgency Plaintiffs allege in their application is a product of

their own creation and continuous disregard for the Federal Rules of Civil

Procedure and Local Rules of this Court. At every turn, Plaintiffs have failed to

appropriately and expeditiously pursue the discovery they now claim is necessary

for the consideration of their motions for preliminary injunction and class

certification (PI and Class Motions) (see ECF Nos. 12 and 13), both of which are

scheduled for a hearing on November 20, 2012, along with the Bipartisan Legal

Advisory Groups (BLAG) motion to dismiss (see ECF Nos. 36-37) and

Defendants Procedural Motion to Dismiss and Partial Motion to Dismiss (see ECF

No. 46).1

There are a number of ways Plaintiffs could have handled these issues without

creating the urgency they now claim and eliminating the need for the instant Ex

Parte Application. Specifically: (1) Plaintiffs could have sought expedited or early

discovery by court order when they filed their complaint, Preliminary Injunction or

Class Certification motions (or at any time shortly thereafter); (2) Plaintiffs could

have sought a court order after Defendants formally objected to their attempt to

propound discovery before discovery was permitted under the Federal Rules of

Civil Procedure, absent a court order; or (3) Plaintiffs could have filed their Motion

to Compel a mere two days earlier, thereby securing a November 5, 2012 hearing

date. Plaintiffs did none of these things and have continued to litigate this case as

if the rules do not apply to them. Such inaction by Plaintiffs does not warrant the

Courts expedited consideration of their motion to compel discovery. This Courtshould deny Plaintiffs request to expedite the November 19, 2012 hearing

1 As Defendants stated in their portion of the Joint Stipulation attached to Plaintiffs Motion to

Compel Discovery, discovery in this case should be stayed in its entirety until the Court resolves

the pending dispositive motions, in addition to the other arguments concerning the need fordiscovery set forth later in this response and in the Joint Stipulation (see ECF 59-1 at 7-20).


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regarding Plaintiffs Motion to Compel, and otherwise deny Plaintiffs request for

expedited review of their Motion to Compel Discovery. In the alternative, to the

extent this Court deems discovery to be appropriate at all, this Court should stay

discovery until this Court has ruled on the pending dispositive motions.

I. Because Plaintiffs Urgency Is a Product of Their Own Creation,They Are Not Entitled to Expedited Discovery or Expedited

Consideration of Their Motion to Compel.

Plaintiffs alleged need for ex parte relief and an order compressing the

normal schedule for a motion to compel is a product of their own creation.

Plaintiffs contend that the expedited schedule is warranted because they need

discovery prior to the Courts November 20, 2012 hearing on Plaintiffs

Preliminary Injunction and Class Motions. Currently, the hearing on Plaintiffs

Motion to Compel is scheduled for the day before that hearing, on November 19,

2012. Plaintiffs not only waited to propound discovery, but when they did, they

did not do so at the proper time under the Federal Rules of Civil Procedure nor did

they seek a Court order to proceed on an expedited time frame until they were up

against the hearing date on their motions. Such actions do not, and should not,

require the Court to expedite the Motion to Compel hearing or otherwise expedite

its consideration of Plaintiffs Motion to Compel.

Plaintiffs delays in this case are numerous. First, Plaintiffs did not file their

motion for preliminary injunction until eight months after Plaintiff Jane DeLeons

I-601 waiver was denied. Plaintiffs filed their Complaint on July 12, 2012. It was

not until August 23, 2012, that Plaintiffs filed their Preliminary Injunction and

Class Motions. At that time, they did not seek any discovery, in fact, they noted

the motions for a September 24, 2012 hearing, which was only about a month after

filing the motions, thereby signaling that the motions could be decided without

discovery.


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Plaintiffs maintain that the compressed briefing schedule is necessary

because they were not alerted of the need for discovery until Defendants filed their

oppositions to Plaintiffs motions. That statement cannot be true. In their Ex Parte

Application, Plaintiffs erroneously stated that Defendants filed their oppositions to

Plaintiffs Preliminary Injunction and Class Motions on September 9, 2012, and

that those oppositions include[d] factual claims on which plaintiffs have sought

relevant discovery. (ECF No. 60 at 2.) Plaintiffs claimed that in response to the

PI and Class Oppositions, they served defendants with a Notice of Deposition

under Rule 30(b)(6) the next day. Those representations are not true. While

Plaintiffs emailed a Notice of Deposition on September 10, 2012, this was done

four days before Defendants filed their Preliminary Injunction and Class

Oppositions on September 14, 2012. (See ECF No. 35, 39.) Accordingly,

Plaintiffs must have determined that discovery was needed prior to reviewing any

responses to its Class and Preliminary Injunction motions which had not even

been filed. Accordingly, Plaintiffs representation that their September 10, 2012

Notice of Deposition was in response to Defendants Oppositions should be

disregarded entirely. Plaintiffs delay in coming to the realization that they desired

discovery should not result in substantial prejudice to Defendants and unnecessary

expedition by this Court.

Moreover, even after deciding that they wanted discovery, Plaintiffs did not

act reasonably or promptly to obtain such discovery in accordance with the Federal

Rules of Civil Procedure. After receiving Plaintiffs deposition notice, counsel for

Defendants informed counsel for Plaintiffs by email that Defendants would not

engage in discovery at that time. (Ex. A.) Defendants followed that with a letteron September 24, 2012, to Plaintiffs counsel, explaining their position regarding

Plaintiffs deposition notice in further detail. (Ex. B.) Defendants noted that the

parties had not yet conferred as required by Federal Rule of Civil Procedure 26(f),

and that, under Rule 26(d)(1), Plaintiffs could not seek discovery without a


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stipulation or Court Order. Defendants made clear that they did not stipulate to

early discovery. The next day, instead of seeking a Court Order allowing

expedited or early discovery, Plaintiffs emailed Defendants written discovery

requests,2 including requests for admission, production of documents, and

interrogatories. (Ex. C.)

On September 27, 2012, counsel for Defendants reiterated to counsel for

Plaintiffs by telephone that, because the parties had not yet conferred pursuant to

Rule 26(f) and Plaintiffs had not obtained a court order, discovery was premature

and that Defendants were not in a position to engage in a formal meet and confer

concerning such issues that time. Defendants noted, however, that they were

amenable to scheduling a Rule 26(f) conference. But on September 28, 2012,

instead of seeking a court order or proposing a Rule 26(f) conference, Plaintiffs

counsel sent Defendants counsel a Proposed Stipulation Regarding Discovery

Dispute, invoking the process set forth in Local Rule 37-1. (Ex. D.) In an

accompanying letter, Plaintiffs request[ed] to confer with defendants in a good

faith effort to eliminate or narrow the parties dispute regarding discovery and to

finalize a joint stipulation pursuant to Local Rule 37-2. (Id.) Plaintiffs also noted

the parties agreed position that under Rule 30(a)(2), plaintiffs may seek leave to

conduct early discovery. (Id.) Again, however, Plaintiffs opted not to seek a

Court Order allowing expedited discovery at that time.

On October 2, 2012, Defendants informed Plaintiffs via letter that, because

the parties still had not conferred under Rule 26(f) and Plaintiffs had not obtained a

court order, both discovery and a motion to compel remained inappropriate. (Ex.

2At that time, the parties had not agreed to electronic service. Plaintiffs re-served their

discovery requests on October 5, 2012, after the parties agreed to service by email during their

Rule 26(f) conference. (Ex. I.) Thus, Plaintiffs Motion to Compel concerning written discovery

is premature because the time has not run for Defendants to respond to Plaintiffs writtendiscovery requests, which, if this Court determines are permitted, would not be due until

November 5, 2012 at the earliest.


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E.) Despite Plaintiffs assertion to the contrary in their Ex Parte Application,

nothing in Defendants October 2 letter references the Administrative Procedure

Act (APA) as Defendants sole basis for objecting to discovery.3

Defendants

suggested in their letter that the parties schedule a prompt Rule 26(f) conference,

and proposed dates and times for such a conference. On October 3, 2012,

Plaintiffs sent a revised Proposed Stipulation Regarding Discovery Dispute to

Defendants. (Ex. F.)

On October 5, 2012, Plaintiffs, Defendants, and BLAG engaged in a Rule

26(f) conference via telephone. During that call, the parties also conducted a

formal meet-and-confer regarding the discovery dispute.4

Defendants indicated

that they would respond with their portion of the joint stipulation within seven

days, in accordance with Local Rule 37-2. Plaintiffs expressed their frustration

with the timeline for submission (as set forth in the rules) and likely resolution of

the Joint Stipulation and indicated they would file an Ex Parte Application instead.

The next week, Plaintiffs reversed course, deciding not to file an Ex Parte

Application and deciding to properly engage in the Motion to Compel Discovery

process outlined in Local Rule 37. The parties complied with Local Rule 37-2 and

prepared a joint stipulation, which Plaintiffs filed as an attachment to their Motion

to Compel on October 17, 2012. (See ECF No. 59-1.) The same day that

Plaintiffs filed their Motion to Compel, Plaintiffs filed the instant Ex Parte

Application. (ECF No. 60.)

3 Defendants merely preserved their prior objection contained in their September 24, 2012 letter,

which included an objection based on the applicability of the APA.

4This was the only formal meet-and-confer conference regarding the present discovery dispute.

Plaintiffs assertion that they conducted several meet and confers is not accurate. While the

parties engaged in conversations and exchanged correspondence concerning these issues, theonly formal meet and confer was on October 5, 2012. (Ex Parte App. at 3, ECF No. 60.)


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Yet again, Plaintiffs own actions created their perceived need for urgency at

this time. Plaintiffs could have avoided the need to expedite their Motion to

Compel by merely filing the motion two days earlier, on October 15, 2012, as they

originally intended.5 If they had filed the Motion to Compel on October 15, 2012,

Plaintiffs could have noticed the hearing for November 5, 2012, more than two

weeks before the hearing on the Preliminary Injunction and Class Motions,

eliminating the need for the Court to expedite the hearing date or to rush its

decision. Instead, Plaintiffs filed the motion on October 17, 2012, which made the

next available motion day November 19, 2012, one day before the Preliminary

Injunction and Class motions hearing. Notably, Defendants were prepared to sign-

off on the stipulation on October 15, 2012 but Plaintiffs failed to deliver the final

motion packet to Defendants for review until October 16, 2012. (See Ex. G, Email

Exchange Between Defendants Counsel and Plaintiffs Counsel.) Once again,

Plaintiffs own actions have created the alleged exigency.

II. If Plaintiffs Discovery Was Essential to Their PreliminaryInjunction and Class Certification Motions, They Should Have

Sought Expedited Discovery Early in the Case.

Plaintiffs crisis is self-created. If Plaintiffs truly believed that discovery is

needed to support their motions, they should have filed a motion for expedited or

early discovery at the same time they filed their Preliminary Injunction and Class

Motions nearly two months ago, see ECF Nos. 12-13 (filed August 23, 2012).

Plaintiffs did not do so. Instead, Plaintiffs sought to invoke the local rules

governing discovery disputes. Plaintiffs should not be exempt from the rules that

they have invoked. Because the compressed schedule that Plaintiffs seek is a

product of their own failure to properly seek the opening of discovery when they

should have, this Court should deny Plaintiffs ex parte relief.

5 Defendants provided Plaintiffs with their portion of the Joint Stipulation on October 12, 2012,

but asked to see the final package (including the Notice of Motion) prior to filing.


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Federal Rule of Civil Procedure 26(d) provides an expedited discovery

mechanism that Plaintiffs could have invoked upon a showing of good cause.

See, e.g.,Apple Inc. v. Samsung Elecs. Co., 768 F. Supp. 2d 1040, 1043 (N.D. Cal.

2011) (noting the grant of one partys request for expedited discovery, while

denying the request of the other party). Plaintiffs did not do so. Under this

mechanism, Plaintiffs could have sought a Court Order as soon as they filed their

complaint on July 12, 2012, even before filing their Preliminary Injunction Motion.

Such expedited discovery could have begun before the meet and confer

requirement outlined in Fed. R. Civ. P. 26(f). While expedited discovery would

not have condensed the parties normal response times allowed for discovery

requests under the Federal Rules of Civil Procedure, it would have allowed

discovery to begin much earlier in the litigation process, and would have provided

an appropriate amount of time in which to litigate such issues.

III. Plaintiffs Have Improperly Used The Ex Parte Process.Not only is Plaintiffs ex parte application to expedite their motion to

compel unwarranted, but their use of the ex parte process is inappropriate. This

Court has previously made clear that ex parte relief is not justified unless the

moving party is without fault in creating the crisis that requires ex parte relief, or

that the crisis occurred as a result of excusable neglect. Mission Power Engg Co.

v. Contl Cas. Co., 883 F. Supp. 488, 492 (C.D. Cal. 1995). Indeed, [e]x parte

applications are not intended to save the day for parties who have failed to present

requests when they should have. Id. at 493 (quotations omitted). Because

Plaintiffs created their own emergency, they are not allowed to pass that

emergency on to the Court and opposing parties.Furthermore, Plaintiffs have violated their obligations under Local Rule 7-

19.1. Under that rule, Plaintiffs must advise the other parties about the substance

of the ex parte application and ascertain the parties position on the application.

C.D. Cal. L.R. 7-19.1. The ex parte applicant must then accurately articulate the


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opposing parties position on the ex parte motion. Id. For purpose of the instant

Ex Parte Application, Plaintiffs made inaccurate representations regarding

Defendants position. On October 16, 2012, counsel for Plaintiffs indicated their

intent to file an ex parte application. In response, counsel for Defendants inquired

about the date on which Plaintiffs would seek to move the November 19, 2012

hearing and when Plaintiffs intended to file such an application. (See Ex. H.)

Counsel for Defendants did not receive a response to that email. Instead,

Plaintiffs represented that Defendants opposed the instant Ex Parte Application.

While Defendants ultimately oppose the relief Plaintiffs seek, it is worth noting

that Plaintiffs failed to accurately depict Defendants position before confirming

the position, as is required pursuant to Local Rule 7-19.1.6

IV. No Discovery is Proper at this Time and Should be Stayed Pendingthe Outcome of the Dispositive Motions.

As laid out in great detail in Defendants Portion of the Stipulation filed in

conjunction with Plaintiffs Motion to Compel Discovery (ECF 59-1, at 7-20),

Discovery is not proper and should be stayed. In support of this position

Defendants have offered numerous reasons, not the least of which is the fact that

there currently are pending two dispositive motions to dismiss (Defendants and

BLAGs) which are based on purely legal arguments and have the potential to

dispose of the entire case. (See ECF 59-1 at 12-14.) In the Joint Stipulation,

Defendants also explained that Plaintiffs Motion to Compel with regard to any

written discovery requests is entirely premature. While Defendants believe

6Local Rules 7-19.1 states:

It shall be the duty of the attorney so applying [for an ex parte application] (a) tomake reasonable, good faith efforts orally to advise counsel for all other parties, if

known, of the date and substance of the proposed ex parte application and (b) to

advise the Court in writing and under oath of efforts to contact other counsel andwhether any other counsel, after such advice, opposes the application.


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discovery should be stayed in its entirety, to the extent any deadline currently

applies to Plaintiffs written discovery requests, Defendants construe such written

responses/objections to be due no earlier than November 5, 2012 (thirty days after

Plaintiffs re-served the requests and the 26(f) conference took place). Now

Plaintiffs are asking this Court to expedite its decision on their already premature

motion to compel.

Defendants have raised numerous arguments showing why discovery is

inappropriate, and showing why if the Court deems it to be appropriate at all, it is

not appropriate on a truncated schedule. These arguments are spelled out between

pages 7 and 20 of the Joint Stipulation re: Discovery Disputes (ECF 59-1) andinclude:

Defendants and BLAGs pending motions to dismiss are based onpurely legal arguments and have the potential to dispose of the entire

litigation. As such, they should be decided before Defendants are

ordered to produce information pertaining to a nationwide class of

individuals on a truncated schedule. (ECF 59-1, at pp. 12-14)

Discovery is not needed (nor have Plaintiffs sought it) for theresolution of the merits of their claims. Indeed, the merits of

Plaintiffs claims i.e., that Section 3 of DOMA is unconstitutional

are questions of law for which there are no issues of fact to be elicited

through discovery. (ECF 59-1, at pp. 14-15)

Discovery is not needed to resolve Plaintiffs preliminary injunctionmotion because, in opposing it, Defendants assumed the facts as laid

out by Plaintiffs in the preliminary injunction motion and relied only

legal argument (as opposed to facts) in their Opposition to the Motion

for a Preliminary Injunction. (ECF 59-1, at pp. 12-14)

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Discovery is not warranted regarding the class certification prior tothe November 20, 2012 hearing because nationwide class-wide

discovery on an extremely compressed timetable would be highly

burdensome and unfair to Defendants. (ECF 59-1, at 17-20)

Plaintiffs delay in seeking the discovery they now claim is needed toresolve their motions for preliminary judgment and class certification

underscores the fact that no such need exists. (ECF 59-1 at 12-20)

Defendants welcome the opportunity to submit further briefing on the issue

as the Court sees fit, as well as the opportunity explain their position at oral

argument currently set for November 19, 2012.

DATED: October 18, 2012 Respectfully submitted,

STUART F. DELERY

Acting Assistant Attorney General

Civil Division

AUGUST E. FLENTJE

Acting Deputy Assistant Attorney General

DAVID J. KLINE

Director

Office of Immigration Litigation

JESI J. CARLSON

Senior Litigation Counsel

s/ Lana L. Vahab

LANA L. VAHAB

DC Bar No. 976203Trial Attorney

Department of Justice, Civil Division





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Tel: (202) 532-4067

Fax: (202) 305-7000


s/ Katherine E.M. GoettelKATHERINE E.M. GOETTEL

IA Bar No. 23821

Trial Attorney

Department of Justice, Civil Division





Tel: (202) 532-4115Fax: (202) 305-7000



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