Proceedings: (IN CHAMBERS) ORDER RE DEFENDANTS’ EX PARTE APPLICATION
FOR STAY PENDING APPEAL [98]
On September 10, 2025, the Court granted Plaintiffs’ Motion for Preliminary Injunction.
[Dkt. 83]. Defendants filed a Notice of Appeal nearly a month later. [Dkt. 89]. The instant Ex
Parte Application for Stay of the Preliminary Injunction Pending Appeal (“Application”) was
filed on October 15. [Dkt. 98].
Defendants contend that immediate, ex parte relief is required in light of the “No Kings”
rally scheduled to take place in Los Angeles (and across the country) on October 18. Application
at 2. They also assert various “workability” concerns and other substantive arguments largely
mirroring those raised and addressed in prior briefing. Id. at 12–31.
To justify ex parte relief, the moving party must show that its “cause will be irreparably
prejudiced if the underlying motion is heard according to regular noticed motion procedures,”
and that it 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 Eng’g Co. v. Cont’l Cas. Co., 883 F.
Supp. 488, 492 (C.D. Cal. 1995).
Here, Defendants waited five weeks after the Court issued its injunction to file their
Application, during which time the Court presumes Defendants complied with its order to
disseminate the injunction. Furthermore, they waited almost three weeks from when they first
indicated to Plaintiffs that they would be seeking a stay. Declaration of Peter Bibring in
Opposition to Application ¶ 2 [Dkt. 100-1] (noting that Defendants notified Plaintiffs of their
intent to move for a stay pending appeal on September 26, 2025). And Defendants waited over a
week from when they first filed their notice of appeal. Indeed, although they now assert urgency
given the upcoming demonstrations, the protest has been well publicized for more than ten days.
See Alexa Mae Asperin, List: 'No Kings' anti-Trump protests in Southern California on Oct. 18,
Fox 11 L.A. (Oct. 7, 2025 at 10:48 PT), https://www.foxla.com/news/no-kings-day-anti-trump-
protests-california-oct-18. In short, Defendants have not shown any exigency not of their own
creation and therefore have not shown an entitlement to extraordinary relief.
Notwithstanding these procedural deficiencies, the Court will address the merits of the
arguments presented. To that end, the Court will issue a substantive order on the stay request no
later than October 24, 2025. Given that a substantive opposition has already been filed, the
matter is deemed submitted until then. All prior orders remain in full force and effect.
IT IS SO ORDERED.
Page 2 of 2 CI
Federal judge denies LAPD emergency motion to let officers to use force against press during #NoKings protest on Saturday.
I’m hearing, unconfirmed, City Council unanimously ordered City Attorney to withdraw motion anyway. Thank you! Much needed oversight!
drive.google.com/file/d/1tVyi...
17.10.2025 21:52 — 👍 206 🔁 77 💬 8 📌 7
Thank you. One of my first requests to public officials has long been to set the right tone. This is appreciated.
I believe first elected in City of Los Angeles to acknowledge issues with LAPD use of force against press since ... Eric Garcetti and Dennis Zine 15 yrs ago?
Hope to see more!
17.10.2025 04:44 — 👍 56 🔁 15 💬 2 📌 0
The official trailer for Blue Zeus is out! The film, narrated by Gerard Butler, will have its West Coast Premiere at the prestigious @newportbeachfilmfest next week. Both screenings sold out but they added a third screening!
15.10.2025 22:12 — 👍 1 🔁 0 💬 0 📌 0
California press protections undermined as violations surged at LA protests
Batons, pepper balls, searches, detainment: How police defied the state’s media rights law
Great overview of police brutality against CA journalists.
LA alone accounts for "nearly half of all press freedom violations reported nationwide so far this year"!
We must hold the line here.
As California goes, so goes the nation.
From my new colleagues @freedom.press/@pressfreedomtracker.us.
02.10.2025 00:46 — 👍 83 🔁 28 💬 1 📌 1
Honored to share that Blue Zeus won Best Documentary at the 41st Boston Film Festival and swept the Equus International Film Festival with 5 awards including Best of Festival! Grateful to our crew & congrats to fellow filmmakers.
#BlueZeus #BFF2025 #EquusFest
29.09.2025 18:30 — 👍 1 🔁 0 💬 0 📌 0
We won!
12.09.2025 20:02 — 👍 1 🔁 0 💬 0 📌 0
So, we sued the DHS and Kristi Noem and we won!
Just after 5:00 p.m. yesterday, Judge Vera issued an order granting our motion for preliminary injunction in LA Press Club v. Noem!
11.09.2025 16:50 — 👍 1 🔁 0 💬 0 📌 0
DOUBLE PREMIERE!
BLUE ZEUS (narrated by Gerard Butler) & GANGSTA GARDENER (featuring Ron Finley) make their New England Premieres at the prestigious 41st Boston Film Festival on Sat, Sept 20:
1:30 PM BPL (Rabb Hall) — FREE
6:00 PM Paramount Theatre
bostonfilmfestival.org #BFF41
27.08.2025 19:02 — 👍 0 🔁 0 💬 0 📌 0
Important weekend read.
Human Rights Watch typically focuses on atrocities far from the United States, but sadly now must shine its powerful global spotlight here in Los Angeles.
Much of the violence they document is directed toward press, potentially silencing those who might expose it.
23.08.2025 19:58 — 👍 301 🔁 158 💬 2 📌 0
LAPD came in to clear and several people have been injured
09.08.2025 05:04 — 👍 98 🔁 46 💬 3 📌 5
Absolutely brutal and unwarranted arrest by DHS in front of the detention center just now
09.08.2025 03:21 — 👍 362 🔁 182 💬 10 📌 10
Here’s the moment LAPD ordered media along with protestors against the wall, despite requests for a supervisor as well as reminders that PC409.7(b) specifically exempts media from dispersal orders. Never made contact with a PIO. didn’t speak with a supervisor for a very long time after being cuffed.
09.08.2025 11:16 — 👍 624 🔁 251 💬 14 📌 20
Letters to Liam: One Family’s Fight to Save Yours
A powerful film about grief, justice, and the fight for change. | Check out 'Letters to Liam: One Family’s Fight to Save Yours' on Indiegogo.
WE NEED YOUR HELP!
We just launched our Indiegogo campaign to complete "Letters to Liam", a powerful documentary that transforms one family's devastating loss into a lifesaving mission.
Please support, share, and become part of Liam's legacy. Check out the new trailer below.
igg.me/at/liamslega...
17.06.2025 22:31 — 👍 0 🔁 0 💬 0 📌 0
Yes, thank you!
11.06.2025 01:01 — 👍 1 🔁 0 💬 1 📌 0
I am the owner along with the victim Plastic Jesus.
11.06.2025 00:52 — 👍 1 🔁 0 💬 1 📌 0
Please help if you can! gofund.me/1af36fd0
10.06.2025 23:46 — 👍 2 🔁 0 💬 1 📌 0
Coming to film festivals soon!
23.05.2025 16:16 — 👍 3 🔁 1 💬 0 📌 0
Sneak peek of our new film Blue Zeus narrated by Gerard Butler And Executive produced by Mathew Rhys and Daryl Hannah!
08.05.2025 20:29 — 👍 30 🔁 8 💬 0 📌 0
I want to take a moment to appreciate and celebrate three amazing women that I have the privilege of collaborating with. Their passion, dedication, and talent make every project better, and I am grateful to work alongside them.
A big thank you to @analisfilms @itslarayray and @rands.winters!
08.03.2025 18:41 — 👍 0 🔁 0 💬 0 📌 0
In news deserts, Trump won in a landslide
Conservative voters – the very ones Trump has targeted with his attacks on the press – “should be helping to lead the drive” to save local news.
News deserts have social consequences for everyone who lives in them // 🧵
localnewsinitiative.northwestern.edu/posts/2024/1...
07.12.2024 01:21 — 👍 209 🔁 56 💬 9 📌 2
We’re thrilled to announce that our film “Gangsta Gardener” starring @ronfinleyhq has won the Best Short Documentary award at the Independent Shorts Awards!
Check out the film in person at the Pittsburgh Shorts Film Festival on Sat Nov 23rd at 1pm at the Harris Theatre in downtown Pittsburgh.
18.11.2024 21:01 — 👍 3 🔁 0 💬 0 📌 0
Our award-winning short film “Gangsta Gardener” starring @ronfinleyhq has been officially selected for the prestigious Pittsburgh Shorts Film Festival @filmpgh!
The Premiere will be November 23rd at 1pm at the historical Harris Theatre in downtown Pittsburgh PA.
filmpittsburgh.org/pages/pittsb...
15.11.2024 18:39 — 👍 0 🔁 0 💬 0 📌 0
Husband and father. 40th Governor of California. Former Lt. Governor of California. Former San Francisco Mayor. Personal account.
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