The opinion of the court was delivered by: Hon. Susan Illston
STIPULATION TO EXTEND TIME FOR PLAINTIFF'S MOTION FOR
ATTORNEYS' FEES AND NON- STATUTORY COSTS
[Civil Local Rule 6-2]
WHEREAS, pursuant to Civil Local Rule 6-2, Plaintiff FREDDIE M. DAVIS and Defendants JAMES E. AYALA and DARRYL GRIFFITH (collectively referred to hereinafter as 3 "the Parties") agree to extend the time for Plaintiff FREDDIE M. DAVIS to file her motion for 4 attorneys' fees and non-statutory costs pursuant to 42 U.S.C. Section 1988 up to and including 5 January 24, 2012; 6
WHEREAS, the Parties agree that good cause exists for this Stipulation because of the sheer volume of this litigation which has spanned a four-year period. Over this litigation, extensive 8 written and deposition discovery was conducted. There was a voluminous dispositive motion for 9 summary judgment, a litany of pretrial motions, and an eighteen (18) day trial. The Parties agree 10 that it would be impossible for Ms. Davis to prepare and file a motion that encompasses a full and 11 accurate appraisal of the attorneys fees and non-statutory costs that she is entitled to claim as a 12 prevailing party to this matter within the fourteen (14) day time frame provided by FRCP 54(d);
WHEREAS, in the interests of justice, and for good cause, the Parties agree to extend the 14 time for Ms. Davis to file her motion in light of the sixty (60) day extension the Court has recently 15 granted Defendant Griffith to file his motion for attorneys' fees (Docket # 203); and 16
WHEREAS, the Parties agree that the aforementioned extension will not affect any 17 scheduling for this case, IT IS HEREBY STIPULATED AND AGREED by the Parties, through 18 their respective attorneys of record, that Plaintiff FREDDIE M. DAVIS shall have an extension to 19 and including January 24, 2012 to file her motion for attorneys' fees and non-statutory costs. It is 20 hereby understood that Defendants reserve any and all rights to oppose any and all aspects of said 21 motion(s).
Dated: December 29, 2011 PRICE AND ASSOCIATES 23 /s/ Pamela Y . Price PAMELA Y. PRICE, Attorneys for Plaintiff FREDDIE M. DAVIS 24 25 Dated: December 29, 2011 ANDRADA & ASSOCIATES 26 /s/ Lynne G. Stocker LYNNE G. STOCKER, Attorneys for Defendants 27 COUNTY OF ALAMEDA, JAMES E. AYALA, And DARRYL GRIFFITH
The Court having read and considered the foregoing Stipulation of the parties, 3 and good cause appearing therefore, IT IS HEREBY ORDERED that the time for filing Plaintiff's 4 5 Motion for attorneys' fees and non-statutory costs pursuant to 42 U.S.C. Section 1988 shall be and hereby is enlarged to January 24, 2012.
HON. SUSAN ILLSTON UNITED STATES DISTRICT COURT
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