1 ERIC GRANT United States Attorney 2 J. DOUGLAS HARMAN Assistant United States Attorney 3 501 I Street, Suite 10-100 Sacramento, CA 95814 4 Telephone: (916) 554-2700 Facsimile: (916) 554-2900 5 Attorneys for Plaintiff 6 United States of America

7 8 IN THE UNITED STATES DISTRICT COURT 9 EASTERN DISTRICT OF CALIFORNIA 10 11 CARMEN RODRIGUEZ RASCON, CASE NO. 1:25-CV-01787-AC

12 Petitioner, STIPULATION REGARDING BRIEFING

SCHEDULE; [PROPOSED] FINDINGS AND

13 v. ORDER

14 TODD LYONS, et al.,

15 Respondents.

16

17 18 Petitioner, Carmen Rodriguez-Rascon, by and through his counsel of record, and Respondents, 19 Todd Lyons et al., by and through their counsel of record, stipulate and agree as follows: 20 1. Petitioner, through counsel, submitted the instant petition for Writ of Habeas Corpus on 21 December 9, 2025. ECF 1. 22 2. On December 16, 2025, Petitioner also filed a motion for Temporary Restraining Order. 23 ECF 6. 24 3. On the same day, the court directed Respondents to show cause as to how the instant case 25 materially differed from others previously decided by this court. Respondents filed their response to the 26 motion for TRO and answer to the underlying habeas petition on December 17, 2025, in compliance 27 with the court’s order. ECF 13. In the Answer, Respondents requested a stay of proceedings pending 28 the resolution of the appeal in Rodriguez Vazquez v. Bostock, 779 F. Supp. 3d 1239 (W.D. Wash. 2025), 1 which concerns substantially similar issues of law as this case, and is scheduled for expedited hearing 2 and resolution before the Ninth Circuit Court of Appeals. ECF 13. 3 4. On December 22, 2025, the court issued an order granting Petitioner’s requested TRO, 4 ordering Respondents to release Petitioner immediately and inform the court of compliance within four 5 days. ECF 15 at 11–12. While the court declined to stay proceedings without providing immediate 6 injunctive relief, the court indicated it wished to consider staying the merits of the petition pending the 7 outcome in Rodriguez Vazquez. Id. at 11. The court also ordered Petitioner to notify the court by no 8 later than January 5, 2026, whether and upon what grounds Petitioner objected to such a stay. Id. at 12. 9 5. Petitioner was released from Respondents’ custody on December 22, 2025, at 7:45 p.m. 10 ECF 17. 11 6. On December 29, 2025, the court converted the TRO to a preliminary injunction (PI) 12 based on the non-opposition of Respondents. ECF 18. In that order, the court directed the parties to 13 meet and confer to submit a joint proposed briefing schedule to the court. Id. 14 7. In compliance with the court’s order, counsel conferred on December 29, 2025. In that 15 meeting, Petitioner’s counsel indicated that Petitioner had no opposition to Respondents’ requested stay 16 of proceedings pending resolution of Rodriguez Vazquez v. Bostock, as long as the court’s preliminary 17 injunction remained in force. 18 /// 19 /// 20 /// 21 /// 22 /// 23 /// 24 /// 25 /// 26 /// 27 /// 28 /// 1 The parties therefore jointly request that the Court issue an order staying proceedings in this 2 matter pending the resolution of Rodriguez Vazquez v. Bostock, 779 F. Supp. 3d 1239 (W.D. Wash. 3 2025) before the Ninth Circuit Court of Appeals. At such time as a ruling is delivered from the Ninth 4 Circuit, the parties will reconvene and file a proposed briefing schedule. 5 6 IT IS SO STIPULATED 7 Dated: December 31, 2025 ERIC GRANT 8 United States Attorney

9 /s/ J. Douglas Harman 10 J. DOUGLAS HARMAN Assistant United States Attorney 11 Attorney for Respondents

12 Dated: December 31, 2025 /s/ Nicole Gorney 13 NICOLE GORNEY Attorney for Petitioner 14

CARMEN RODRIGUEZ RASCON

15

16

17 18 19 20 21 22 23 24 25 26 27 28 ' {PROPOSED}| O RD ER 2 3 IT IS HEREBY ORDERED that the proceedings in case 1:25-CV-01787-AC are STAYED 4 || pending the resolution of the appeal of Rodriguez Vazquez v. Bostock, 779 F. Supp. 3d 1239 (W.D. 5 || Wash. 2025) before the Ninth Circuit Court of Appeals. At such time as a ruling is issued in that case, 6 || the parties are directed to meet and confer for the purpose of submitting a joint proposed briefing 7 || schedule for the petition in this case. 8 ° Dated: J 5, 2026 ated: January 5,

11 UNITED STATES MAGISTRATE JUDGE 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28