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    Case 3:13-Cv-01159 Document 34 Filed 12/06/13 Page 1 of 4 Pageid #: 492

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    The defendants filed an unopposed motion requesting leave to file a response in opposition to the plaintiff's motion for a preliminary injunction that is longer than the page limit. They argue that additional pages are necessary to adequately address the significant and complex constitutional issues raised, as the plaintiff's supporting memorandum was approximately 40 pages. The plaintiffs do not oppose the relief sought of allowing the defendant's response to be up to 28 pages.

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    Case 3:13-Cv-01159 Document 34 Filed 12/06/13 Page 1 of 4 Pageid #: 492

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    The defendants filed an unopposed motion requesting leave to file a response in opposition to the plaintiff's motion for a preliminary injunction that is longer than the page limit. They argue that additional pages are necessary to adequately address the significant and complex constitutional issues raised, as the plaintiff's supporting memorandum was approximately 40 pages. The plaintiffs do not oppose the relief sought of allowing the defendant's response to be up to 28 pages.

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    3:13-cv-01159 #34

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    The defendants filed an unopposed motion requesting leave to file a response in opposition to the plaintiff's motion for a preliminary injunction that is longer than the page limit. They argue that additional pages are necessary to adequately address the significant and complex constitutional issues raised, as the plaintiff's supporting memorandum was approximately 40 pages. The plaintiffs do not oppose the relief sought of allowing the defendant's response to be up to 28 pages.

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    Download as PDF, TXT or read online from Scribd
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    21 views4 pages

    Case 3:13-Cv-01159 Document 34 Filed 12/06/13 Page 1 of 4 Pageid #: 492

    Uploaded by

    Equality Case Files
    The defendants filed an unopposed motion requesting leave to file a response in opposition to the plaintiff's motion for a preliminary injunction that is longer than the page limit. They argue that additional pages are necessary to adequately address the significant and complex constitutional issues raised, as the plaintiff's supporting memorandum was approximately 40 pages. The plaintiffs do not oppose the relief sought of allowing the defendant's response to be up to 28 pages.

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    IN THE UNITED STATES DISTRICT COURT FOR THE MIDDLE DISTRICT OF TENNESSEE AT NASHVILLE VALERIA TANCO and SOPHY

    JESTY, et al., Plaintiffs, vs. WILLIAM EDWARD BILL HASLAM, as Governor of the State of Tennessee, in his official capacity, et al., Defendants. ) ) ) ) ) ) ) ) ) ) )

    Case No. 3:13-cv-01159 Judge Trauger Magistrate Judge Griffin

    DEFENDANTS UNOPPOSED MOTION FOR LEAVE TO FILE A RESPONSE IN OPPOSITION TO PLAINTIFFS MOTION FOR PRELIMINARY INJUNCTION IN EXCESS OF PAGE LIMIT

    Come now Defendants William Edward Bill Haslam, Governor of the State of Tennessee, Bill Gibbons, Commissioner of the Department of Safety and Homeland Security, Larry Martin, Commissioner of the Department of Finance and Administration, and Robert E. Cooper, Attorney General and Reporter for the State of Tennessee, in their official capacities, by and through the undersigned, pursuant to Local Rule 7.01(a) for leave to file a Response in Opposition to Plaintiffs Motion for Preliminary Injunction of twenty-eight (28) pages or less. Good cause exists to grant Defendants motion because of the significance and complexity of the constitutional issues raised in this matter. Additionally, Plaintiffs filed a Memorandum in Support of their Motion for Preliminary Injunction of approximately forty (40) pages. Defendants have endeavored to present their legal arguments in as concise a manner as possible,

    Case 3:13-cv-01159 Document 34 Filed 12/06/13 Page 1 of 4 PageID #: 492

    however, the additional pages are necessary to adequately address all of the issues raised by the Plaintiffs. Defendants counsel has conferred with Plaintiffs counsel with respect to this motion, and the Plaintiffs do not oppose the relief sought. Premises considered, Defendants move for leave to file a Response in Opposition to Plaintiffs Motion for Preliminary Injunction of twenty-eight (28) pages or less.
    Respectfully submitted,

    ROBERT E. COOPER, JR. Attorney General and Reporter s/Martha A. Campbell MARTHA A. CAMPBELL #14022 Deputy Attorney General General Civil Division Cordell Hull Building, Second Floor P. O. Box 20207 Nashville, TN 37214 (615) 741-6420 martha.campbell@ag.tn.gov s/Kevin Steiling KEVIN STEILING #10631 Deputy Attorney General Civil Litigation and State Services Division Cordell Hull Building, Second Floor P. O. Box 20207 Nashville, TN 37214 (615) 741-2370 kevin.steiling@ag.tn.gov

    Case 3:13-cv-01159 Document 34 Filed 12/06/13 Page 2 of 4 PageID #: 493

    CERTIFICATE OF SERVICE I hereby certify that on December 6, 2013, a copy of the foregoing was filed electronically. Notice of this filing will be sent by operation of the Courts electronic filing system to all parties indicated on the electronic filing receipt. Parties may access this filing through the Courts electronic filing system. Abby R. Rubenfeld # 6645 2409 Hillsboro Road, Suite 200 Nashville, Tennessee 37212 (615) 386-9077 arubenfeld@rubenfeldlaw.com William L. Harbison # 7012 Phillip F. Cramer # 20697 J. Scott Hickman # 17407 John L. Farringer IV # 22783 SHERRARD & ROE, PLC 150 3rd Avenue South, Suite 1100 Nashville, Tennessee 37201 (615) 742-4200 bharbison@sherrardroe.com pcramer@sherrardroe.com shickman@sherrardroe.com jfarringer@sherrardroe.com Maureen T. Holland # 15202 HOLLAND AND ASSOCIATES, PLLC 1429 Madison Avenue Memphis, Tennessee 38104-6314 (901) 278-8120 mtholland@aol.com Regina M. Lambert # 21567 7010 Stone Mill Drive Knoxville, Tennessee 37919 (865) 679-3483 lambertregina@yahoo.com Shannon P. Minter Christopher F. Stoll Asaf Orr NATIONAL CENTER FOR LESBIAN RIGHTS 870 Market Street, Suite 370 San Francisco, California 94102 (415) 392-6257 sminter@nclrights.org
    127197

    Case 3:13-cv-01159 Document 34 Filed 3 12/06/13 Page 3 of 4 PageID #: 494

    cstoll@nclrights.org aorr@nclrights.org

    s/ Martha A. Campbell MARTHA A. CAMPBELL #14022 Deputy Attorney General General Civil Division Office of the Attorney General P.O. Box 20207 Nashville, TN 37202 (615) 741-6420

    127197

    Case 3:13-cv-01159 Document 34 Filed 4 12/06/13 Page 4 of 4 PageID #: 495

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