STIPULATION AND ORDER GRANTING TEMPORARY RESTRAINING ORDER AND ORDER TO SHOW CAUSE RE: PRELIMINARY INJUNCTION

RICHARD G. SEEBORG, District Judge.

Pursuant to Civ. L.R. 7-12, the Parties to this action submit the following stipulation and proposed order:

RECITALS

1. This action was filed on June 1, 2014, seeking, among other things, to enjoin Defendant COUNTY OF ALAMEDA ("County") from any and all conduct enforcing the Alameda County Code of Ordinances ("Code") to prohibit, encumber, or penalize the display of certain signs ("Signs") on 8555 Dublin Canyon Road within the County (the "Parcel"), such signs being owned and operated by Plaintiff CITIZENS FOR FREE SPEECH, LLC ("Citizens") pursuant to agreement with Plaintiff MICHAEL SHAW, the owner of the Parcel.

2. Postmarked June 10, 2014, the County issued a "Declaration of Public Nuisance — Notice to Abate" from the Alameda County Community Development Agency Planning commission signed by investigator of the Code Enforcement Division Paul da Silva ("Notice"), which ordered the removal of the Signs pursuant to the Code. The Notice required the Signs be removed within 10 days of the postmarked date.

3. On June 12, 2014, Plaintiffs filed a Motion for temporary restraining order and order to show cause re: preliminary injunction to enjoin the County's enforcement of the Code as against the Signs ("Motion").

4. The County does not concede that Plaintiffs have met their burden in establishing irreparable injury, inadequacy of legal remedies, and imminent harm in bringing the Motion.

5. The Parties wish to resolve the matter between them for the present time by staying the enforcement of the Code against Plaintiffs, while providing the County additional time to respond to the Motion for a preliminary injunction.

6. Accordingly, the Parties have agreed to a stipulated temporary restraining order as follows, pending a hearing on Plaintiff's Motion for preliminary injunction.

7. County withdraws the Notice pending a hearing on the Plaintiff's Motion for preliminary injunction.

8. The Parties request that the County's Opposition to the Motion be due no sooner than June 27, 2014.

9. Plaintiff's Motion shall remain their moving papers, reserving the right to file amended or supplemental papers should changed circumstances warrant.

STIPULATION

Wherefore, the Parties agree: Defendant County and its employees, agents, officers, managers, delegates, or assigns and those in active concert or participation with it or them ARE HEREBY TEMPORARILY RESTRAINED AND ENJOINED from any conduct enforcing the Code against Plaintiffs or investigating alleged violations of the Code by Plaintiffs.

Defendant County is ordered to show cause at 10:00 a.m. on July 25, 2014, or as soon thereafter as counsel may be heard in the courtroom of the Honorable Charles R. Breyer, Courtroom 6, located at 450 Golden Gate Avenue, 17th Floor, San Francisco, California, why it, its employees, agents, officers, managers, delegates, or assigns and those in active concert or participation with it or them should not be restrained and enjoined pending trial of this action from any and all conduct to prohibit, encumber, or penalize Plaintiffs and/or Plaintiffs property, including the Signs pursuant to the Code as against the Signs.

Defendant County waives any bond requirement.

Defendant County's response or opposition to the Motion for Preliminary injunction shall be due no earlier than June 27, 2014.

IT IS SO STIPULATED.

Pursuant to Civ. L.R. 5-1(i)(3), I attest that all signatories whose signatures appear herein have concurred in this document, and that I maintain records in support of said concurrence for introduction to the Court, if so ordered.

PURSUANT TO STIPULATION, IT IS SO ORDERED.