GONZALES & GONZALES BONDS AND INSURANCE AGENCY, INC., Plaintiff,
UNITED STATES DEPARTMENT OF HOMELAND SECURITY, Defendant.
Gary A. Nye, Esq., David R. Ginsburg, Esq., ROXBOROUGH, POMERANCE, NYE & ADREANI, LLP Woodland Hills, California, 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 REDINGM, (CSBN 226864), Assistant United States Attorney, San Francisco, California, 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 have agreed in principle to a settlement 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 parties have drafted a settlement agreement and expect to be able to finalize the agreement once the timing of the settlement payment is determined. The parties should know this very shortly.
The current filing deadline for the motion and bill of costs is August 2, 2013. The parties agree that an extension to August 9, 2013 should allow for enough time to enter into a written settlement agreement. The parties therefore respectfully request that the Court approve this requested extension.
This is the eighth 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 August 2, 2013 to August 9, 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 will ...