Beavers v. City of Turlock, et al.

Filing 38

STIPULATION and ORDER granting an extension to November 27, 2018, to file dispositional documents and/or a motion for attorney's fees and costs, as prescribed by the Court's Minute Order memorializing the parties' acceptance of the mediator's proposal (ECF No. [34)]. Order signed by Magistrate Judge Erica P. Grosjean on 11/16/2018. (Rooney, M)

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Sanjay S. Schmidt (SBN 247475)
LAW OFFICE OF SANJAY S. SCHMIDT
1388 Sutter Street, Suite 810
San Francisco, CA 94109
T: [phone]
F: [phone]
e-mail: [e-mail]
Panos Lagos (SBN 61821)
LAW OFFICES OF PANOS LAGOS
5032 Woodminster Lane
Oakland, CA 94602
T: [phone]
F: [phone]
e-mail: [e-mail]
Attorneys for Plaintiff,
RANDY BEAVERS

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UNITED STATES DISTRICT COURT

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EASTERN DISTRICT OF CALIFORNIA

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RANDY BEAVERS,

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Plaintiff,
vs.
CITY OF TURLOCK, a municipal
corporation, et al.,
Defendants.

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Case No. 1:16-cv-01878-LJO-BAM
STIPULATION TO EXTEND
DEADLINE FOR FILING OF MOTION
FOR ATTORNEY’S FEES & COSTS;
ORDER
(ECF No. 37)

TO THE CLERK OF THE COURT, ALL PARTIES, AND THEIR ATTORNEYS
OF RECORD:
Plaintiff RANDY BEAVERS (“Plaintiff”) and Defendants CITY OF TURLOCK, et al.,
hereby respectfully request a three-week extension of the deadline by which to file dispositional

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documents and/or a motion for attorney’s fees and costs, from November 6, 2018, as prescribed

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by the first extension from the original date prescribed by the Court’s Minute Order

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memorializing the parties’ acceptance of the mediator’s proposal (ECF No. 34), September 7,

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2018, to November 27, 2018, in order to provide the parties with additional time within which to
Stipulation & Order Re: Deadline for Filing of Motion for Fees & Costs
Beavers v. City of Turlock, et al.
USDC (E.D. Cal.) Case No.: 1:16-cv-01878-LJO-BAM

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meet-and-confer, and potentially obviate the need to litigate a motion.
As noted above, this is the second extension requested by the parties. The reason is for
the extension is that Plaintiff’s counsel has been awaiting an Order on a motion for attorney’s
fees in a different matter that is also venued in the Eastern District, which counsel anticipated
would be directly instructive as to the rates for counsel in this case.

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Respectfully submitted,
Dated: November 15, 2018

LAW OFFICES OF SANJAY S. SCHMIDT

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By:

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Dated: November 15, 2018

/s/ Sanjay S. Schmidt
SANJAY S. SCHMIDT
Attorneys for Plaintiff
RANDY BEAVERS

LAW OFFICES OF PANOS LAGOS

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By:

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/s/ Panos Lagos
PANOS LAGOS
Attorneys for Plaintiff
RANDY BEAVERS

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Dated: November 15, 2018
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ALLEN, GLAESSNER,
HAZELWOOD & WERTH, LLP

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By:

/s/ Kevin P. Allen
DALE L. ALLEN, JR.
KEVIN P. ALLEN
Attorneys for Defendants
CITY OF TURLOCK; GREGORY W.
ROTON; DUSTIN M. FERREIRA; GABRIEL
GONZALEZ; and PAUL INDERBITZEN

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Stipulation & Order Re: Deadline for Filing of Motion for Fees & Costs
Beavers v. City of Turlock, et al.
USDC (E.D. Cal.) Case No.: 1:16-cv-01878-LJO-BAM

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ORDER

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Pursuant to the stipulation of the parties (ECF No. 37), and finding good cause,

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IT IS ORDERED that the parties are granted an extension to November 27, 2018 to file
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dispositional documents and/or a motion for attorney’s fees and costs, as prescribed by the
Court’s Minute Order memorializing the parties’ acceptance of the mediator’s proposal (ECF

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No. 34).
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IT IS SO ORDERED.
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Dated:

November 15, 2018

/s/
UNITED STATES MAGISTRATE JUDGE

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Stipulation & Order Re: Deadline for Filing of Motion for Fees & Costs
Beavers v. City of Turlock, et al.
USDC (E.D. Cal.) Case No.: 1:16-cv-01878-LJO-BAM

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