I just got a call from Aundra Jiles, whom we featured in this article in 2022. Her call made my day. www.themarshallproject.org/2022/08/04/p...
Beth Schwartzapfel
@journo-beth.bsky.social
6.3K followers 454 following 212 posts
Writer, reader, nerd. Reporter for The Marshall Project covering criminal (in)justice, esp LGBTQ+, parole, addiction, health. Host of VIOLATION. It's not on us to complete the work—but neither can we stop doing it.
![PARTE APPLICATION
PLEASE TAKE NOTICE that, in accordance with Local Rule 7-19 and this
Court's Civil Standing Order Section XIII, Defendants City of Los Angeles and Chief Jim McDonnell ("City" or "Defendants"), by and through their counsel of record, respectfully apply to this Court on an ex parte basis for an order staying the Preliminary Injunction entered on September 10, 2025 (ECF No. 83) pending appeal. This Application is based on Federal Rules of Civil Procedure, Rule 62 and Federal Rules of Appellate Procedure, Rule 8(a)(1)(A), the accompanying Memorandum of Points and Authorities, the Declarations of Lt. Joseph Dunster, the Declaration of Richard Egger, other supporting declarations and exhibits, the record, and any further evidence or argument the Court may permit.
Good Cause and Urgency
Good cause and urgency exist for the relief requested. The City has filed a
Notice of Appeal of the Preliminary Injunction. In addition, the City faces imminent enforcement obligations under the Court's September 10, 2025, Preliminary Injunction Order ("Order") because there is an upcoming "No Kings" protest scheduled for Saturday, October 18, 2025, which requires it to deploy officers subject to the constraints of the Order. The Order enjoins the Los Angeles Police Department ("LAPD") from a broad range of actions relating to its handling of "journalists" during protests, and requires LAPD to take a number of affirmative actions, described in the accompanying Memorandum of Points and Authorities below. Although the Court described the injunction as "mirror[ing] the Defendants' own policies" (Order at p. 27), it imposes ambiguous mandates that create serious operational uncertainty and a substantial risk of contempt for good-faith conduct to preserve public safety. Given the immediate and concrete risk to officer and public safety posed by these uncertainties-and the fact that the City has](https://cdn.bsky.app/img/feed_thumbnail/plain/did:plc:vnsn3gjqvtaianuuziyiqxlx/bafkreiclgogepwv2z33rjia2tx4jubo6tmhl7sy6gp6nptv4xirwcppiqu)
