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Daniel Stephanie Enyart v. National Conference of Bar Examiners

UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA


November 11, 2011

DANIEL STEPHANIE ENYART
PLAINTIFF,
v.
NATIONAL CONFERENCE OF BAR EXAMINERS, INC.,
DEFENDANT.

LAURENCE W. PARADIS (CA Bar No. 122336) ANNA LEVINE (CA Bar No. 227881) 2 DISABILITY RIGHTS ADVOCATES 3 2001 Center Street, Fourth Floor Berkeley, CA 94704 4 Telephone: (510) 665-8644 Facsimile: (510) 665-8511 5 Email: general@dralegal.org 6 SCOTT C. LABARRE (pro hac vice) LABARRE LAW OFFICES, P.C. 7 1660 S. Albion Street, Suite 918 Denver, CO 80222 8 Telephone: (303) 504-5979 9 Fax: (303) 757-3640 slabarre@labarrelaw.com 10 10 11 11 DANIEL F. GOLDSTEIN (pro hac vice) BROWN, GOLDSTEIN & LEVY, LLP 12 12 120 E. Baltimore St., Suite 1700 ADVOCATES ADVOCATES Baltimore, MD 21202 94704-1204 94704-1204 LOOR LOOR 13 13 Telephone: (410) 962-1030 F F Fax: (410) 385-0869 HIRD HIRD 14 dfg@browngold.com ALIFORNIA T T , , 15 Attorneys for Plaintiff RIGHTS RIGHTS TREET TREET 665-8644 665-8644 (510) (510) GREGORY C. TENHOFF (154553)(tenhoffgc@cooley.com) S ALIFORNIA S 16 16 17 17 WENDY J. BRENNER (198608) (brennerwj@cooley.com) DISABILITY ENTER , DISABILITY ENTER C C 2001 ERKELEY 18, C ERKELEY C LAURA A. TERLOUW (260708) (lterlouw@cooley.com) COOLEY LLP Five Palo Alto Square 19 19 3000 El Camino Real 20 20 Palo Alto, CA 94306-2155 Telephone: (650) 843-5000 21 21 Facsimile: (650) 857-0663 22 22 ROBERT A. BURGOYNE (pro hac vice) FULBRIGHT & JAWORSKI L.L.P. 23 801 Pennsylvania Avenue, N.W., Suite 500 24 24 Washington, D.C. 20004 Telephone: (202) 662-0200 25 25 Facsimile: (202) 662-4643 (rburgoyne@fulbright.com) 26 26 Attorneys for Defendant National Conference of Bar Examiners 27 27 28 B B

STIPULATED REQUEST TO ENLARGE TIME FOR FILING OF PLAINTIFF'S MOTION FOR FEES AND COSTS AND BILL OF COSTS.

ADVOCATES ADVOCATES

DISABILITY DISABILITY

ENTER ENTER

2001 ERKELEY

ERKELEY 18

I. Action Requested

Pursuant to Civil L.R. 6-2 and Civil L.R. 7-12 plaintiff Stephanie Enyart and defendant National Conference of Bar Examiners ("NCBE") (hereinafter, "the parties"), 4 jointly stipulate and request an order extending by 30 days the filing deadline for 5 Plaintiff's motion for attorneys fees and costs and bill of costs, to December 4, 2011. 6

II. Stipulation Regarding Requested Action

IT IS HEREBY STIPULATED between and among the parties, by and through their respective counsel of record, subject to the approval of the Court, which plaintiff 9 and defendant jointly request, as follows: 10

WHEREAS, on November 4, 2011, this Court entered final judgment for Plaintiff;

WHEREAS, to advance judicial economy and an expeditious resolution to the litigation, the parties wish to explore the resolution of Plaintiff's claim for attorneys' fees and costs through settlement;

WHEREAS, the parties agree that they will be unable to complete a good faith negotiation regarding Plaintiff's claim for attorneys' fees and costs within the fourteen- day period provided by Civil L.R. 54-5(a) and Fed. R. Civ. P. Rule 54(d)(2)(b); (510) (510) 17

WHEREAS, the parties have not previously requested or received any time modifications for the motion for attorneys fees and costs; and

WHEREAS, the proposed time extension will at most delay resolution of the attorneys' fees component of this case by only 16 days, but may expedite the resolution 21 21 of the case by clarifying and narrowing any remaining terms of disagreement following 22 22 negotiation, or by obviating the need for motion practice entirely. 23 23

B B

THE PARTIES HEREBY STIPULATE AS FOLLOWS:

1. The period during which the Plaintiff must file any motion for attorney's fees

3 and costs and bill of costs shall be extended from within 14 days of entry of judgment by 4 the Court, to within 30 days of entry of judgment by the Court. The new deadline for 5

Plaintiff's motion for attorney's fees and bill of costs shall be December 5, 2011 (the first 6 court day following the extension). 7

Enyart v. National Conference of Bar Examiners, et al., Case No.: C09-05191 CRB STIPULATED MOTION TO EXTEND THE FILING DEADLINE TO FILE PLAINTIFF'S MOTION FOR FEES AND COSTS.

PURSUANT TO STIPULATION, IT IS SO ORDERED

HARLES R.

REYER

District of California A

United

I States

IS SO ORDERED IT

Northern

Charles Breyer Judge

District Judge,

ALIFORNIA

(510) (510)

DISABILITY DISABILITY

ENTER ENTER

2001 2001 ERKELEY

ERKELEY

20111111

© 1992-2011 VersusLaw Inc.



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