U.S. Federal District Court, Carr v. Reed et al and Carr v. Oregon et al

Ninth Circuit Appeal, Washington

• On December 31, 2007, I mailed a Brief (eight copies and the original) to the court and two copies to each of the opposing counsel.
• On January 11, 2008, I submitted a motion asking that a Portland panel be assigned to this case so that any hearings will be in Portland, OR.
• On January 15, 2008, the state's counsel submitted a Notice of a different attorney in this matter.
• On January 28, 2008, the Clark County defendants submitted their very short Brief, basically deferring to state's defendants.
• On January 30, 2008, the state's defendants submitted their Brief which I got on February 2, 2008.
• On Feburary 15, 2008, I mailed my Reply Brief (eight copies and the original) to the court and two copies to each of the opposing counsel.

Oregon Suit

• Doc1 - I filed the complaint. The html version has a link to a pdf text version and the court's scanned pdf version.
• Doc2 - On March 31, 2008, the clerk filed the standard assignment order.
• Doc3 - On April 7, 2008 I filed a brief motion to get access to CM/ECF.
• Doc4 (no document) - On April 9, 2008 the court denied my brief motion. So I prepared a more complete one. What a bother!
• Doc5 - On April 21, 2008 I filed my longer motion
• Doc6 - The clerk chose to file the Memorandum of Law as a separate document.
• Doc7 - Along with the Declaration.
• Doc8 - I also received the Portland Waiver of Service.
• Doc8A - Along with the Exhibit.
• Doc9 - Then I received the Oregon Acceptance of Service.
• Doc10 (no document) - On April 29, 2008 the court granted in part my longer motion.
• Doc11 - On May 15, 2008I filed my third motion, geez.
• Doc12 - along with a memorandum of law,
• Doc13 - and my declaration.
• Doc14 (no document) - On May 29, 2008 the court denied my motion.
• Doc15 - Also on May 29, 2008 the city filed a Motion for Extension
• Doc16 - along with the supporting declaration.
• Doc17 - Also on May 29, 2008 the state filed a Motion for Extension
• Doc18 - along with the supporting declaration.
• Doc19 - On June 3, 2008 the city filed a Motion to Dismiss
• Doc20 - along with the Memorandum of Law and
• Doc21-1 - and a Declaration
  1. Doc21-2 - Exhibit 1 Order from Western Washington District Court
  2. Doc21-3 - Exhibit 2 Temporary Order, unredacted, link is to redacted version
  3. Doc21-4 - Exhibit 3 Order for Protection, unredacted, link is to redacted version
  4. Doc21-5 - Exhibit 4 Order, Court of Appeals
  5. Doc21-6 - Exhibit 5 Order, Oregon Supreme Court
  6. Doc21-7 - Exhibit 6 Mandate, Washington Court of Appeals
  7. Doc21-8 - Exhibit 7 Complaint
• Doc22 - On June 3, 2008 the state filed a Motion to Dismiss
• Doc23 - along with the Memorandum of Law.
• Doc24 (no document) - On June 10, 2008 the court sealed documents Doc21-3 and Doc21-4.
• Doc25 - On June 9, 2008, I filed a motion for an extension of time
• Doc26 - and my declaration.
• Doc27 (no document) - On June 11, 2008 the court granted extension of time.
• Doc28 - On June 25, 2008, I filed a Reply
• Doc29-1 - and my declaration with
• Doc29-2 Exhibit 1 - Arrest Record
• Doc29-3 Exhibit 2 - Redacted Temporary Order of Protection
• Doc29-4 Exhibit 3 - Redacted Order of Protection
• Doc29-5 Exhibit 4 - Constitutional Commissioner Appointment Orders
• Doc29-6 Exhibit 5 - State's Opposition to Seal Record
• Doc29-7 Exhibit 6 - Multnomah County Circuit Court Decision
• Doc29-8 Exhibit 7 - Transcript of Hearing
• Doc29-9 Exhibit 8 - Order Approving Transcript
• Doc30 - On July 29, 2008, the city filed a Motion for Extension in Deadlines
• Doc31 - and the supporting Declaration.
• Doc32 (no document) - On August 5, 2008 the court granted motion for extension of discovery & PTO deadlines.
• Doc33 - On August 8, 2008, I filed a Motion to Amend the Complaint
• Doc33-1 - with a Supplement
• Doc34 - and a Memorandum of Law
• Doc35 - and a Declaration, but forgot the exhibits. Doh!
• Doc36 Note: this is a huge file, 5 meg, with the exhibits and missing the signature page it might be better to get the separate pieces which were on the CD I provided.
  On August 12, 2008 I filed an Amended Declaration, with
  1. Exhibit 1, the parking citation of April 23, 2008,
  2. Exhibit 2, my response to the parking unit of May 23, 2008,
  3. Exhibit 3, the accpetance of service of June 12, 2008, and
  4. Exhibit 4, the response of the parking unit of July 23, 2008.
• Doc37 - On August 13, 2008 the state filed a Response.
• Doc38 - and the city filed a Response.
• Separately I will be filing a Motion for Summary Judgment in the parking citation.
• Doc39 - and my Response.
• On August 19, 2008 city sent me a request for production of documents.
• On September 2, 2008 city sent me a reminder to the judge.
• On September 17, 2008 I delivered three boxes of documents to the city with my response.
• Doc40 - On September 29, 2008, the judge denied the request to amend the complaint.
• Doc41 - On October 20, 2008, the judge dismissed the complaint. I was wondering why it was taking so long as it was pretty much a foregone conclusion this would be the result. Now we are off to the 9th Circuit Court.
• Doc42 - On October 21, 2008, the judge closed the case.
• Doc43 - On October 28, 2008, I filed a Notice of Appeal.
• Sent - and the Civil Appeal Docketing Statement.
• Doc44 - On November 3, 2008, the Court of Appeals set the Time Schedule.

Ninth Circuit Appeal, Oregon

• On November 11, 2008 I submitted my motion along with the exhibits of:
  • Order of April 29. 2008,
  • Order of May 29. 2008,
  • Page One of the electronic version of the Complaint, and
  • Page One of the scanned version of the Complaint.
• On November 12, 2008, the city sent me a letter informing me that a different attorney will be handling the appeal.

This page was last updated on November 15, 2008.