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Francisca Moralez v. Whole Foods Marketcalifornia

UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA


April 25, 2013

FRANCISCA MORALEZ,
PLAINTIFF,
v.
WHOLE FOODS MARKETCALIFORNIA, INC.; BOND CC APPLICATION OAKLAND LLC; AND DOES 1-10, INCLUSIVE
DEFENDANTS.

The opinion of the court was delivered by: Hon. Charles R. Breyer United States Judge

[Complaint Filed March 2, 2012]

[Amended Complaint Filed May 10, 2012]

JOINT STIPULATION TO EXTEND TIME FOR PLAINTIFF TO FILE ATTORNEY FEE

WHEREAS, defendant made a FRCP Rule 68 offer of judgment on April 2, 2013(later 2 amended), and plaintiff accepted it on April 15, 2013; 3

WHEREAS, the notice of acceptance of the Rule 68 offer of judgment will be filed 4 concurrently with this stipulation; 5

WHEREAS, the offer of judgment specifically excluded any attorney fees and 6 contemplated that plaintiff's counsel will make application to this Court to recover attorney fees, 7 litigation expenses and costs; 8

THEREFORE, the parties stipulate and request the Court to set the following briefing 9 schedule for plaintiff's counsel's application for attorney fees, litigation expenses and costs. 10

Plaintiff's counsel shall file her application on or before May 31, 2013, defendants shall file their 11 opposition on or before June 14, 2013, and plaintiff's counsel shall file her reply on or before June 12 21, 2013. 13

Respectfully submitted, 14 15 Dated: April 16, 2013 16 LAW OFFICES OF PAUL L. REIN 17 18 By /s/ Celia McGuinness PAUL L. REIN 19 CELIA McGUINNESS CATHERINE M. CABALO 20 Attorneys for Plaintiff 21 FRANCISCA MORALEZ 22 Dated: April 16, 2013 23 SHEPPARD, MULLIN, RICHTER & HAMPTON LLP 24 25 By /s/ Hayley S. Grunvald RICHARD J. SIMMONS 26 DEREK R. HAVEL HAYLEY S. GRUNVALD Attorneys for Defendant BOND CC OAKLAND, LLC

SIGNATURE CERTIFICATION

Pursuant to Section 2(f)(4) of the Electronic Case Filing Administrative Policies and Procedures Manual, I hereby certify that the content of this document is acceptable to Hayley S. Grunvald, counsel for Defendant Bond CC Oakland and that I have obtained Ms. Grunvald's 5 authorization to affix her electronic signature to this document.

Dated: April 16, 2013 LAW OFFICES OF PAUL L. REIN By /s/ Celia McGuinness PAUL L. REIN CELIA McGUINNESS CATHERINE M. CABALO Attorneys for Plaintiff FRANCISCA MORALEZ

ORDER

Having reviewed and considered the above Stipulation of the parties, and good cause appearing, the Court sets the following briefing schedule for plaintiff's counsel's application for attorney fees, litigation expenses and costs: Plaintiff's counsel shall file her 4 application on or before May 31, 2013, defendant shall file their opposition on or before June 14, 5 2013, and plaintiff's counsel shall file her reply on or before June 21, 2013. 6 7

PURSUANT TO STIPULATION, IT IS SO ORDERED. 8 9

20130425

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