G.P.P., Inc. v. Guardian Protection Products, Inc.

Filing 501

STIPULATION AND ORDER REGARDING DEADLINE FOR BILL OF COSTS. Order signed by Magistrate Judge Sheila K. Oberto on 12/21/2021. (Kusamura, W)

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COLLEEN BAL (SBN 167637)
JOHN P. FLYNN (SBN 141094)
WILSON SONSINI GOODRICH & ROSATI
Professional Corporation
One Market Plaza
Spear Tower, Suite 3300
San Francisco, California 94105
Telephone: [phone]
Facsimile: [phone]
Email: [e-mail]; [e-mail]

STUART A. WILLIAMS (pro hac vice)
WILSON SONSINI GOODRICH & ROSATI
Professional Corporation
375 Southpointe Boulevard
Canonsburg, Pennsylvania 15317
Telephone: [phone]
Facsimile: [phone]
Email: [e-mail]

DYLAN J. LIDDIARD (SBN 203055)
WILSON SONSINI GOODRICH & ROSATI
Professional Corporation
650 Page Mill Road
Palo Alto, California 94304
Telephone: [phone]
Facsimile: [phone]
Email: [e-mail]
Attorneys for Plaintiff
UNITED STATES DISTRICT COURT
EASTERN DISTRICT OF CALIFORNIA
FRESNO DIVISION

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)
G.P.P., INC. d/b/a GUARDIAN INNOVATIVE )
SOLUTIONS,
)
)
Plaintiff,
)
)
v.
)
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GUARDIAN PROTECTION PRODUCTS, INC., )
and RPM WOOD FINISHES GROUP, INC.,
)
)
Defendants.
)
)

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STIPULATION AND [PROPOSED] ORDER
CASE NO. 1:15-CV-00321-SKO

Case No. 1:15-cv-00321-SKO
STIPULATION AND ORDER
REGARDING DEADLINE FOR
BILL OF COSTS
(Doc. 500)
Courtroom: 7 (Sixth Floor)
Judge: Hon. Sheila K. Oberto

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WHEREAS, the Court entered judgment in this matter on December 13, 2021, Dkt. 499;

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WHEREAS, under Local Rule 292, the current deadline to file bills of costs is December

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27, 2021 and the current deadline to file motions for attorneys’ fees is January 10, 2022;

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WHEREAS, plaintiff G.P.P. Inc. d/b/a Guardian Innovative Solutions (“GIS”), intends to

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file a motion pursuant to FRCP 50(b) on or before January 10, 2022, which will toll the deadline

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to file motions for attorneys’ fees until twenty-eight (28) days after the Court issues its Order on

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GIS’s FRCP 50(b) motion. See, e.g., Bailey v. Cty. of Riverside, 414 F.3d 1023, 1025 (9th Cir.

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2005); Hopkins v. Wells Fargo Bank, N.A., No. 2:13-444 WBS CKD, 2014 U.S. Dist. LEXIS

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89612, at *2-3 n.4 (E.D. Cal. July 1, 2014);

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WHEREAS, the parties have met and conferred and agreed that the deadline to file bills of
costs should be continued to match the deadline to file motions for attorneys’ fees;

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WHEREAS, the parties believe that there is good cause to extend the deadline to file bills

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of costs due to the upcoming holidays and to avoid duplicative briefing on issues common to both

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bills of costs and motions for attorneys’ fees;

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WHEREAS, the parties have not sought any prior extensions of the deadline to file bills of
costs;
THEREFORE, the parties hereby stipulate and respectfully request that the Court order

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that: the deadline for any party to file a bill of costs shall be the same day as the applicable

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deadline to file a motion for attorneys’ fees, and that the applicable deadline to file both a bill of

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costs and a motion for attorneys’ fees shall be twenty-eight (28) days after the Court’s ruling on

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GIS’s anticipated FRCP 50(b) motion in accordance with FRCP 54, E.D. Cal. L.R. 293, and

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applicable law. In the event GIS does not file such a motion, then the parties request that motions

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for fees and bills of cost be due on or before February 7, 2022 (28 days after the January 10, 2022

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deadline for a Rule 50(b) motion).

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STIPULATION AND ORDER
CASE NO. 1:15-CV-00321-SKO

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IT IS SO STIPULATED.

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Dated: December 20, 2021

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Respectfully submitted,

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WILSON SONSINI GOODRICH & ROSATI
Professional Corporation

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By:

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Attorneys for Plaintiff

s/ Colleen Bal

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GORDON & REES LLP

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By:
s/ Aaron Rudin
(as authorized on December 20, 2021)

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Attorneys for Defendants

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ORDER

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Pursuant the parties’ above stipulation (Doc. 500), and for good cause shown,

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IT IS HEREBY ORDERED that the deadline for any party to file a bill of costs shall be the

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same day as the applicable deadline to file a motion for attorneys’ fees, and that the applicable

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deadline to file both a bill of costs and a motion for attorneys’ fees shall be twenty-eight (28) days

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after the Court’s ruling on Plaintiff GIS’s anticipated Rule 50(b) motion. In the event GIS does not

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file a Rule 50(b) motion, the parties’ motions for fees and bills of cost shall be filed by no later than

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February 7, 2022.

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IT IS SO ORDERED.
Dated:

/s/ Sheila K. Oberto

December 21, 2021

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UNITED STATES MAGISTRATE JUDGE

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STIPULATION AND ORDER
CASE NO. 1:15-CV-00321-SKO

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