Carmen Rodriguez Rascon v. Todd Lyons, et al.

1 ERIC GRANT United States Attorney J. DOUGLAS HARMAN Assistant United States Attorney 501 I Street, Suite 10-100 Sacramento, CA 95814 Telephone: (916) 554-2700 Facsimile: (916) 554-2900 Attorneys for Plaintiff United States of America 8 IN THE UNITED STATES DISTRICT COURT 9 EASTERN DISTRICT OF CALIFORNIA CARMEN RODRIGUEZ RASCON, CASE NO. 1:25-CV-01787-AC 12 Petitioner, STIPULATION REGARDING BRIEFING SCHEDULE; [PROPOSED] FINDINGS AND 13 v. ORDER TODD LYONS, et al., 15 Respondents.

18 Petitioner, Carmen Rodriguez-Rascon, by and through his counsel of record, and Respondents, 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 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 materially differed from others previously decided by this court. Respondents filed their response to the motion for TRO and answer to the underlying habeas petition on December 17, 2025, in compliance with the court’s order. ECF 13. In the Answer, Respondents requested a stay of proceedings pending the resolution of the appeal in Rodriguez Vazquez v. Bostock, 779 F. Supp. 3d 1239 (W.D. Wash. 2025), which concerns substantially similar issues of law as this case, and is scheduled for expedited hearing 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, ordering Respondents to release Petitioner immediately and inform the court of compliance within four days. ECF 15 at 11–12. While the court declined to stay proceedings without providing immediate injunctive relief, the court indicated it wished to consider staying the merits of the petition pending the outcome in Rodriguez Vazquez. Id. at 11. The court also ordered Petitioner to notify the court by no 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) based on the non-opposition of Respondents. ECF 18. In that order, the court directed the parties to 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 meeting, Petitioner’s counsel indicated that Petitioner had no opposition to Respondents’ requested stay of proceedings pending resolution of Rodriguez Vazquez v. Bostock, as long as the court’s preliminary injunction remained in force.

18 /// /// /// /// /// /// /// /// /// /// /// 1 The parties therefore jointly request that the Court issue an order staying proceedings in this matter pending the resolution of Rodriguez Vazquez v. Bostock, 779 F. Supp. 3d 1239 (W.D. Wash. 2025) before the Ninth Circuit Court of Appeals. At such time as a ruling is delivered from the Ninth Circuit, the parties will reconvene and file a proposed briefing schedule.

6 IT IS SO STIPULATED Dated: December 31, 2025 ERIC GRANT 8 United States Attorney /s/ J. Douglas Harman 10 J. DOUGLAS HARMAN Assistant United States Attorney 11 Attorney for Respondents Dated: December 31, 2025 /s/ Nicole Gorney 13 NICOLE GORNEY Attorney for Petitioner CARMEN RODRIGUEZ RASCON

' {PROPOSED}| O RD ER 3 IT IS HEREBY ORDERED that the proceedings in case 1:25-CV-01787-AC are STAYED || 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, || the parties are directed to meet and confer for the purpose of submitting a joint proposed briefing || schedule for the petition in this case. ° Dated: J 5, 2026 ated: January 5, 11 UNITED STATES MAGISTRATE JUDGE