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 6 regarding G&G's motion for attorney's fees and bill of costs based on the Court's Order of 7 Freedom of Information Act case. The most recent discussion occurred on March 12, 2013, 9 and the parties expect to continue discussions over the next couple weeks. The parties' mutual 10 goal is to resolve the fee and cost issue without the need for motion work and a hearing on the 11 matter. 12
The current filing deadline for the motion and bill of costs is March 19, 2013. Based
13 on their most recent meet and confer, the parties agree that an extension to April 2, 2013 would 14 allow for further meaningful discussion. The parties therefore respectfully request that the 15
This is the fourth requested extension of the original January 4, 2013 deadline.
DHS' deadline for filing opposition to G&G's motion for attorney's fees and bill of
18 costs would continue to be 30 days from the filing of G&G's motion and bill of costs. 19
21 motion for attorney's fees and bill of costs. 22 23 24 25 26 27 28
Plaintiff Gonzales & Gonzales Bonds and Insurance Agency, Inc. ("G&G" or
G&G and DHS are continuing to engage in meaningful meet and confer discussions
December 21, 2012, which ruled upon the parties' motions for summary judgment in this 8 Court approve this requested extension. 16
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
Respectfully submitted, 2 Dated: March 13, 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 13, 2013 MELINDA HAAG 9 United States Attorney 10 /s/ Ann Marie Reding 11 ANN MARIE REDING ...