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234 Opposition To State Request For Extension

The plaintiff opposes the defendants' motion for a 7-day extension to file a supplemental reply brief. The plaintiff argues that the defendants, who have over 2,600 attorneys representing them, do not need more time. Additionally, the supplemental brief has not even been filed yet. The plaintiff contends that the case needs to continue progressing through the court without further delay. The plaintiff requests that the court deny the defendants' motion for an extension.

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152 views4 pages

234 Opposition To State Request For Extension

The plaintiff opposes the defendants' motion for a 7-day extension to file a supplemental reply brief. The plaintiff argues that the defendants, who have over 2,600 attorneys representing them, do not need more time. Additionally, the supplemental brief has not even been filed yet. The plaintiff contends that the case needs to continue progressing through the court without further delay. The plaintiff requests that the court deny the defendants' motion for an extension.

Uploaded by

NoloContendere
Copyright
© © All Rights Reserved
We take content rights seriously. If you suspect this is your content, claim it here.
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Download as PDF, TXT or read online on Scribd
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Case: 12-17808, 06/04/2020, ID: 11710595, DktEntry: 234, Page 1 of 4

UNITED STATES COURT OF APPEALS


NINTH CIRCUIT

GEORGE K. YOUNG JR., )


)
Plaintiff-Appellant, ) No. 12-17808
vs. )
)
STATE OF HAWAII, ET AL., )
)
Defendants - Appellees. )
)

Appellant’s Opposition to Appellees’ Motion for Extension of Time to File the


Parties’ Supplemental En Banc Reply Briefs

Comes now the Plaintiff-Appellant George K. Young, Jr. and for his

Opposition to Appellees’ Motion for Extension of Time to File the Parties’

Supplemental En Banc Reply Briefs (“Motion”), states as follows:

Appellees filed their Motion on June 3, 2020 seeking seven (7) extra days to

file an optional reply to a supplemental brief that hasn’t even been filed yet.

Appellees claim good cause because of the “complex issues presented” and that

“[c]ounsel for Defendants-Appellees has several arguments and briefing deadlines

set between now and the time the supplemental reply briefing is due.” Motion at ¶

4.

This shouldn’t be taken seriously. Their motion has ten attorneys listed on it.

The law firm handling this matter has over 2,600 attorneys.1 Mr. Young has two (2)

1
https://www.law.com/law-firm-profile/?id=143&name=Hogan-Lovells
Case: 12-17808, 06/04/2020, ID: 11710595, DktEntry: 234, Page 2 of 4

lawyers. One of the “good cause” reasons is that they had a reply brief due

yesterday. This is a day before the supplemental brief is even due and before a

purported reply could even be started. That the Defendants-Appellees are state and

local government entities doesn’t mean anything. The Attorney General of Hawaii

is listed on the Motion and will (presumably) be working on the brief. They have

the entire State’s legal team (and the County’s) behind them. So, 2,600 attorneys

plus however many the State and County have to potentially work on this reply?

The Defendants-Appellees don’t need extra time. They need to file their brief

on time (if they even want to, as it is an optional reply) as set by this Court and this

case needs to continue to progress through this Court without any further delay.

Respectfully submitted, this the 4th day of June 2020.

s/ Alan Beck
Alan Beck (HI Bar No. 9145)

s/ Stephen D. Stamboulieh
Stephen D. Stamboulieh
Case: 12-17808, 06/04/2020, ID: 11710595, DktEntry: 234, Page 3 of 4

CERTIFICATE OF COMPLIANCE
1. This response complies with the length limitation of Circuit Rule 27-

1(d) because it is less than 20 pages, excluding the parts of the document exempted

by Circuit Rule 27-1(d).

2. This response complies with the typeface requirements of Federal Rule of

Appellate Procedure 32(a)(5) and the typestyle requirements of Federal Rule of

Appellate Procedure 32(a)(6) because it has been prepared in a proportionally

spaced typeface using Microsoft Office 365 in Times New Roman 14-point font.

s/ Stephen D. Stamboulieh
Stephen D. Stamboulieh
Case: 12-17808, 06/04/2020, ID: 11710595, DktEntry: 234, Page 4 of 4

CERTIFICATE OF SERVICE
On this, the 4th day of June 2020, I served the foregoing pleading by

electronically filing it with the Court’s CM/ECF system which generated a Notice

of Filing and effects service upon counsel for all parties in the case. I declare under

penalty of perjury that the foregoing is true and correct.

Executed this, the 4th day of June 2020.

s/ Stephen D. Stamboulieh

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