GONZALES & GONZALES BONDS AND INSURANCE AGENCY, INC., Plaintiff,
UNITED STATES DEPARTMENT OF HOMELAND SECURITY, Defendant.
Gary A. Nye, Esq. (Cal. Bar No. 126104), David R. Ginsburg, Esq. (Cal. Bar No. 210900), ROXBOROUGH, POMERANCE, NYE & ADREANI, LLP, Woodland Hills, California, Email: email@example.com; firstname.lastname@example.org, Attorneys for Plaintiff Gonzales & Gonzales Bonds and Insurance Agency, Inc.
MELINDA HAAG (CSBN 132612), United States Attorney, ALEX G. TSE (CSBN 152348), Chief, Civil Division, ANN MARIE REDING (CSBN 226864), Assistant United States Attorney, San Francisco, California, Email: email@example.com, Attorneys for Defendant, United States Department of Homeland Security
STIPULATION AND [PROPOSED] ORDER EXTENDING THE DEADLINE FOR PLAINTIFF TO FILE MOTION FOR ATTORNEY'S FEES AND BILL OF COSTS
DONNA M. RYU, Magistrate Judge.
Plaintiff Gonzales & Gonzales Bonds and Insurance Agency, Inc. ("G&G" or "Plaintiff") and Defendant United States Department of Homeland Security ("DHS"), by and through their respective counsel, make the following representations and stipulate and agree as follows:
G&G and DHS are continuing to engage in meaningful meet and confer discussions regarding G&G's motion for attorney's fees and bill of costs based on the Court's Order of December 21, 2012, which ruled upon the parties' motions for summary judgment in this Freedom of Information Act case. The most recent discussion occurred on May 2, 2013, and the parties expect to continue discussions over the next couple months. The parties' mutual goal is to resolve the fee and cost issue without the need for motion work and a hearing on the matter.
The current filing deadline for the motion and bill of costs is May 15, 2013. Based on their most recent meet and confer, the parties agree that an extension to July 17, 2013 would allow for further meaningful discussion. The parties therefore respectfully request that the Court approve this requested extension.
This is the sixth 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 costs would continue to be 30 days from the filing of G&G's motion and bill of costs.
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 motion for attorney's fees and bill of costs.
Pursuant to the stipulation by the parties, the Court extends from May 15, 2013 to July 17, 2013, the deadline for G&G to file its motion for attorney's fees and its bill of costs. DHS' deadline to file opposition to G&G's motion for attorney's fees and bill of costs ...