UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA - OAKLAND DIVISION
March 11, 2013
GONZALES & GONZALES BONDS AND INSURANCE AGENCY, INC., PLAINTIFF,
UNITED STATES DEPARTMENT OF HOMELAND SECURITY, DEFENDANT.
The opinion of the court was delivered by: Honorable Donna M. Ryu
STIPULATION AND [PROPOSED] ORDER EXTENDING THE DEADLINE FOR PLAINTIFF TO FILE MOTION FOR ATTORNEY'S FEES AND BILL OF COSTS
"Plaintiff") and Defendant United States Department of Homeland Security ("DHS"), by and 3 through their respective counsel, make the following representations and stipulate and agree as 4 follows: 5 G&G and DHS are continuing to engage in meet and confer efforts regarding G&G's 6 motion for attorney's fees and bill of costs based on the Court's Order of December 21, 2012, 7 which ruled upon the parties' motions for summary judgment in this Freedom of Information 8 The current filing deadline for the motion and bill of costs is March 12, 2013. The 10 parties seek to extend this deadline by one week, to March 19, 2013, to allow for additional 11 time to meet and confer. The parties respectfully request that the Court approve this requested 12 extension.
Plaintiff Gonzales & Gonzales Bonds and Insurance Agency, Inc. ("G&G" or Act case. 9
DHS' deadline for filing opposition to G&G's motion for attorney's fees and bill of costs 15 would continue to be 30 days from the filing of G&G's motion and bill of costs. 16 17 18 motion for attorney's fees and bill of costs. 19 20 21 22 23 24 25 26 27 28 The requested extension would not affect the schedule for the case. Nothing herein shall constitute a waiver of DHS' right to oppose or object to G&G's
This is the third requested extension of the original January 4, 2013 deadline.
Dated: March 8, 2013 ROXBOROUGH, POMERANCE, NYE & ADREANI, LLP 3 /s/ David R. Ginsburg 4 Gary A. Nye David R. Ginsburg 5 Attorneys for Plaintiff Gonzales & Gonzales Bonds and Insurance 6 Agency, Inc. 7 8 Respectfully submitted, Dated: March 8, 2013 MELINDA HAAG 9 United States Attorney 10 /s/ Ann Marie Reding 11 ANN MARIE REDING Assistant United States Attorney 12 Attorneys for Defendant 13 Department of Homeland Security
DHS' deadline to file opposition to G&G's motion for attorney's fees and bill of costs will 5 remain 30 days from the filing of G&G's motion and bill of costs.
Pursuant to the stipulation by the parties, the Court extends from March 12, 2013 to March 19, 2013, the deadline for G&G to file its motion for attorney's fees and its bill of costs.
IT IS SO ORDERED.
THE HONORABLE DONNA M. RYU UNITED STATES MAGISTRATE JUDGE
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