Arnold v. La Quinta Corporation et al

Filing 68

STIPULATION and ORDER for Extension to File a Motion for Attorneys' Fees, Litigation Expenses and Costs, signed by Chief Judge Anthony W. Ishii on 5/3/11: Motion ddl CONTINUED from May 13, 2011 to July 12, 2011. (Hellings, J)

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PATRICIA BARBOSA, Esq. (SBN 125865)
JEFF A. HARRISON, Esq. (SBN 151227)
BARBOSA, METZ & HARRISON, LLP
17547 Ventura Blvd., Suite 310
Encino, CA 91316
Tel: [phone]
Fax: [phone]
[e-mail]
[e-mail]

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Attorneys for Plaintiff, CONNIE ARNOLD

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GARY R. BASHAM, Esq. (SBN 130119)
BASHAM LAW GROUP
701 University Ave., Suite 220
Sacramento, CA 95825
Tel: [phone]
Fax: [phone]
[e-mail]

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Attorneys for Defendant, IC KANG CORPORATION

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UNITED STATES DISTRICT COURT

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EASTERN DISTRICT OF CALIFORNIA

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CONNIE ARNOLD,

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Plaintiff,
vs.
LA QUINTA CORPORATION,

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Defendants.

) Case No.: 1:08-CV-01246-AWI-DLB
)
) Civil Rights
) Assigned to Honorable Anthony W. Ishii, Judge
presiding
)
) STIPULATION FOR EXTENSION TO FILE
) A MOTION FOR ATTORNEYS’ FEES,
) LITIGATION EXPENSES AND COSTS
)
)
)

On or about January 31, 2011, Plaintiff CONNIE ARNOLD and Defendant IC KANG
CORPORATION submitted to this Court a fully executed Consent Decree and [Proposed] Order for
Settlement of Plaintiff’s Claims for Damages as Against Defendant IC Kang Corporation. This
Court executed the Order on February 12, 2011. (Docket #66).
The Consent Decree and Order provide “The actual amount of the reasonable attorneys’
fees, litigation expenses and costs to be paid by La Quinta to Plaintiff’s counsel shall be determined
________________________________________________________________________________________________
STIPULATION FOR EXTENSION TO FILE A MOTION FOR ATTORNEYS’ FEES, LITIGATION EXPENSES
AND COSTS
Case No.: 1:08-CV-01246-AWI-DLB
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through a settlement between the parties hereto or by the Court through a Motion for an Award of

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Attorneys’ Fees, Litigations Expenses and Costs.” (Docket #66, 3:24-27).

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The Consent Decree and Order further provides that if a motion is required to determine the

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amount of attorneys’ fees, litigation expenses and costs, such motion would have to be “filed by

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Plaintiff’s counsel no later than ninety (90) days of the Court’s execution of the [Proposed]

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Order…” (Docket #66, 5:8-13).

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The parties hereto desire to attempt to settle the issue of attorneys’ fees, litigation expenses

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and costs due Plaintiff’s counsel to the extent possible, as opposed to incurring additional attorneys’

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fees, expenses and costs to file a motion and prepare for a hearing.

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The parties have been in settlement discussions, but have been unable to get a response from
Defendant’s insurance carrier, but have agreed to continue to do so.

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The parties desire to extend the time by which Plaintiff’s counsel must file a Motion for an

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Award of Attorneys’ Fees, Litigation Expenses and Costs for an additional sixty (60) days, so that

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the parties can continue to attempt to settle the attorneys’ fees, litigation expenses and costs portion

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of this matter.

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IT IS SO STIPULATED.

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Dated: April 27, 2011

BARBOSA, METZ & HARRISON, LLP

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By:

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Date: April 27, 2011

___/s/ Jeff A. Harrison____________________
PATRICIA BARBOSA, Esq.
JEFF A. HARRISON, Esq.
Attorneys for Plaintiff, CONNIE ARNOLD
BASHAM LAW GROUP

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By:

___/s/ Gary Basham______________________
GARY R. BASHAM, Esq.
Attorneys for Defendant, IC KANG
CORPORATION

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________________________________________________________________________________________________
STIPULATION FOR EXTENSION TO FILE A MOTION FOR ATTORNEYS’ FEES, LITIGATION EXPENSES
AND COSTS
Case No.: 1:08-CV-01246-AWI-DLB
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ORDER

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Pursuant to Joint Stipulation of Plaintiff, CONNIE ARNOLD and Defendant, IC KANG
CORPORATION, this Court hereby Orders as follows:
The deadline to file a Motion for an Award of Attorneys’ Fees, Litigation Expenses and

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Costs is continued from May 13, 2011 to July 12, 2011.

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IT IS SO ORDERED.
Dated: May 3, 2011
CHIEF UNITED STATES DISTRICT JUDGE
DEAC_Signature-END:

0m8i788

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________________________________________________________________________________________________
STIPULATION FOR EXTENSION TO FILE A MOTION FOR ATTORNEYS’ FEES, LITIGATION EXPENSES
AND COSTS
Case No.: 1:08-CV-01246-AWI-DLB
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