Coleman, et al v. Schwarzenegger, et al

Filing 4117

STIPULATION and ORDER signed by Judge Lawrence K. Karlton on 11/15/2011 ORDERING that pursuant to the stipulation of the parties, and good cause appearing, this Court extends the stay of all outstanding attorneys' fees, costs, and expenses matte rs related to the Three-Judge Court, and related appeals, including the proceedings before the Supreme Court of the United States. The unresolved fees, costs, and expenses related to these proceedings are separate from the fees, costs, and expenses t hat have been resolved by stipulation between the Prison Law Office and Defendants and the Plata v. Brown court's order. Plaintiffs shall submit their motion for fees, costs, and expenses on the aforementioned matter no later than 12/16/2011. Fo r the duration of the stay, any and all deadlines relating to motions or claims for attorneys' fees, costs, and expenses contained in the Federal Civil Rules, the Federal Appellate Rules, the U.S. Supreme Court Rules, and/or the Local Rules for the Eastern District of California do not apply. (Zignago, K.)

1 DONALD SPECTER – 083925
STEVEN FAMA – 099641
2 PRISON LAW OFFICE
1917 Fifth Street
3 Berkeley, California 94710-1916
Telephone: [phone]
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MICHAEL W. BIEN – 096891
ERNEST GALVAN – 196065
AARON J. FISCHER – 247391
ROSEN, BIEN & GALVAN, LLP
315 Montgomery Street, Tenth Floor
San Francisco, California 94104-1823
Telephone: [phone]

WARREN E. GEORGE – 053588
5 CLAUDIA CENTER – 158255
THE LEGAL AID SOCIETY –
BINGHAM MCCUTCHEN LLP
Three Embarcadero Center
6 EMPLOYMENT LAW CENTER
San Francisco, California 94111-4066
180 Montgomery Street, Suite 600
Telephone: [phone]
7 San Francisco, California 94104-4244
Telephone: [phone]
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Attorneys for Plaintiffs
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UNITED STATES DISTRICT COURT
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EASTERN DISTRICT OF CALIFORNIA
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RALPH COLEMAN, et al.,

Case No. Civ S 90-0520 LKK-JFM

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Plaintiffs,
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v.
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EDMUND G. BROWN, Jr., et al.,
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Defendants.

STIPULATION AND ORDER TO
EXTEND TIME IN WHICH TO FILE
MOTION FOR FEES, COSTS AND
EXPENSES RELATED TO WORK
BEFORE THREE-JUDGE COURT
AND SUPREME COURT OF THE
UNITED STATES

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Judge: Hon. Lawrence K. Karlton
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[569180-1]

1.

On June 15, 2011, the Court granted an extension to the stay of all attorneys’

fees, costs and expenses matters related to the Three-Judge Court, and related appeals,
including the proceedings before the Supreme Court of the United States, ordering that
Plaintiffs’ application for fees, costs and expenses be submitted 60 days after August 26,
2011. On October 25, 2011, the Court extended the stay to November 18, 2011.
2.

The parties continue to meet and confer regarding Plaintiffs’ attorneys’ fees,

costs, and expenses. These fees, costs, and expenses are separate from those approved in
the recent order issued by the court in Plata v. Brown. (See Coleman Docket No. 4094.)
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STIPULATION AND [PROPOSED] ORDER TO EXTEND TIME IN WHICH TO FILE MOTION FOR FEES, COSTS AND
EXPENSES RELATED TO WORK BEFORE THREE-JUDGE COURT AND SUPREME COURT OF THE UNITED STATES

1 The purpose of this meet and confer process has been to exhaust any possibility of settling
2 these matters, or of narrowing the disputes as much as possible. In order to allow that
3 process to continue and, if possible, to succeed, the parties jointly request a further
4 extension that provides additional time to meet and confer.
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3.

The parties therefore request that the Court extend the deadline for filing the

6 fees and costs application for matters related to the Three-Judge Court, and related appeals,
7 including the appeal to the Supreme Court of the United States to December 16, 2011. The
8 parties agree that the hearing will not be noticed for January 13th or 20th, 2012.
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IT IS SO STIPULATED.

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11 DATED: Nov. 15, 2011

Respectfully submitted,

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ROSEN, BIEN & GALVAN, LLP

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By: /s/ Ernest Galvan
Ernest Galvan

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Attorneys for Plaintiffs

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17 DATED: Nov. 15, 2011
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CALIFORNIA DEPARTMENT OF JUSTICE
OFFICE OF THE ATTORNEY GENERAL
By: /s/ Debbie Vorous
Debbie Vorous
Deputy Attorney General
Attorneys for Defendants

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[569180-1]

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STIPULATION AND [PROPOSED] ORDER TO EXTEND TIME IN WHICH TO FILE MOTION FOR FEES, COSTS AND
EXPENSES RELATED TO WORK BEFORE THREE-JUDGE COURT AND SUPREME COURT OF THE UNITED STATES

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ORDER

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Pursuant to the stipulation of the parties, and good cause appearing, this Court

3 extends the stay of all outstanding attorneys’ fees, costs, and expenses matters related to
4 the Three-Judge Court, and related appeals, including the proceedings before the Supreme
5 Court of the United States. The unresolved fees, costs, and expenses related to these
6 proceedings are separate from the fees, costs, and expenses that have been resolved by
7 stipulation between the Prison Law Office and Defendants and the Plata v. Brown court’s
8 order. Plaintiffs shall submit their motion for fees, costs, and expenses on the
9 aforementioned matter no later than December 16, 2011. For the duration of the stay, any
10 and all deadlines relating to motions or claims for attorneys’ fees, costs, and expenses
11 contained in the Federal Civil Rules, the Federal Appellate Rules, the U.S. Supreme Court
12 Rules, and/or the Local Rules for the Eastern District of California do not apply.
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IT IS SO ORDERED.

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15 DATED: November 15, 2011
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[569180-1]

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STIPULATION AND [PROPOSED] ORDER TO EXTEND TIME IN WHICH TO FILE MOTION FOR FEES, COSTS AND
EXPENSES RELATED TO WORK BEFORE THREE-JUDGE COURT AND SUPREME COURT OF THE UNITED STATES