IN THE CIRCUIT COURT OF THE STATE OF OREGON FOR THE COUNTY OF MARION JANE DOES 1, 2, 3 and 4, | | No. Plaintiffs, | | STIPULATED MOTION FOR v. | PRELIMINARY INJUNCTION | | THE STATE OF OREGON; JOHN A. | (Expedited Decision Requested) KITZHABER, Governor of Oregon; | and EDWARD JOHNSON, State | Registrar of the Center for Health | Statistics in Oregon, | | Defendants. | ___________________________________|
Pursuant to Oregon Rules of Civil Procedure 79, Plaintiffs and Defendants herein, through their undersigned counsel of record, hereby move the Court for the entry of a preliminary injunction restraining Defendants and their agents and employees, during the pendency of this action, and until the Time of entry ofjudgment, from proceeding on December 3, 1998 and thereafter with the enforcement of Measure No. 58, which was passed by the voters of the State of Oregon on November 3, 1998.
This Stipulated Motion for Preliminary Injunction is supported by Plaintiffs' Complaint filed contemporaneously herewith, the Affidavits of Plaintiffs and their counsel attached hereto as Exhibits A through E, and the Court's records and files herein.
By entering into this Stipulation, Defendants do not admit or accept as true the allegations set forrh in the Complaint or the testimony as set forth in the attached Affidavits, and they reserve all objections and defenses.
IT IS SO STIPULATED- Dated:__11/30___1998. BULLIVANT HOUSER BAILEY A Professional Corporation By__________________________ I Franklin Hunsaker 72131 Loren D. Podwill 84324 Attorneys for Plaintiffs Dated:_________ 1998. HARDY MYERS Attorney General |S| Katherine G. Georges Katherine C. Georges 84231 Assistant Attorney General Trial Attorney Attorneys for Defendants
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