Sullivan v. The Prudential Insurance Company of America et al
Filing
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STIPULATION and ORDER signed by District Judge Troy L. Nunley on 2/12/15. Plaintiff's motion for attorney's fees and costs shall be filed no later than 2/19/15. (Manzer, C)
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DONAHUE & HORROW, LLP
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MICHAEL B. HORROW (SBN 162917)
NICHOLE D. PODGURSKI (SBN 251240)
DONAHUE & HORROW, LLP
1960 E. Grand Ave., Suite 1215
El Segundo, California 90245
Telephone: (310) 322-0300
Facsimile: (310) 322-0302
Email: mhorrow@donahuehorrow.com
Email: npodgurski@donahuehorrow.com
ERIC RATINOFF (SBN 166204)
KERSHAW, CUTTER & RATINOFF, LLP
401 Watt Avenue
Sacramento, CA 95864
Telephone: (916) 448-9800
Facsimile: (916) 669-4499
Email: eratinoff@kcrlegal.com
Attorneys for Plaintiff,
OTILIA SULLIVAN
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UNITED STATES DISTRICT COURT
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EASTERN DISTRICT OF CALIFORNIA
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OTILIA SULLIVAN,
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Case No.: 2:12-cv-01173-TLN-DAD
Plaintiff,
Assigned for All Purposes to the
Honorable Judge Troy L. Nunley
vs.
THE PRUDENTIAL INSURANCE
COMPANY OF AMERICA; PHH
CORPORATION GROUP EMPLOYEE
BENEFIT PLAN, and DOES 1 through 300,
inclusive,
STIPULATION AND ORDER RE
ADDITIONAL TIME FOR
PLAINTIFF TO FILE A MOTION
FOR ATTORNEYS FEES AND
RECOVERY OF COSTS
Defendants.
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Plaintiff Otilia Sullivan (“Plaintiff”) and Defendant The Prudential Insurance
Company of America (“Prudential”) enter this Stipulation based on the following:
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Case No.:2:12-cv-01173-GEB-DAD
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STIPULATION AND ORDER BY THE PARTIES REGARDING 10 DAY CONTINUANCE
REGARDING PLAINTIFF’S MOTION FOR ATTORNEYS’ FEES AND COSTS
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WHEREAS, on October 22, 2014 the Court entered the Parties’ Proposed
Judgment in favor of Plaintiff. (See Doc. No. 68). Plaintiff, as the prevailing party in
this litigation, may apply to the Court for an award of attorneys’ fees and recovery of
costs of action. Pursuant to the Court’s October 22, 2014 order, any application for an
award of attorneys’ fees and recovery of costs of action is due to be filed no later than
December 6, 2014. (See Doc. No. 68). Pursuant to this Court’s order, this date was
continued to January 20, 2015 and then extended to February 9, 2015. (See Doc. No. 70).
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DONAHUE & HORROW, LLP
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WHEREAS, on February 4, 2015 the Parties have reached a resolution
regarding the award of attorney’s fees and costs. The Parties are preparing the
necessary paperwork and assert that it will take approximately 10 additional days to
prepare the final paperwork and for payment to be distributed.
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Therefore, the Parties, by and through their counsel of record, stipulate and
agree that while the agreement with respect to attorneys fees and costs is being
finalized, Plaintiff shall have an additional ten (10) days to file any motion for an
award of attorneys’ fees and recovery of costs in this action. Plaintiff’s motion for
attorneys’ fees and costs shall be filed no later than February 19, 2015.
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The foregoing proposed stipulation is respectfully submitted.
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IT IS SO STIPULATED.
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DATED: February 12, 2015
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DONAHUE & HORROW, LLP
/s/Nichole Podgurski______
Nichole Podgurski
Attorney for Plaintiff
Otilia Sullivan
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Case No.:2:12-cv-01173-GEB-DAD
–2–
STIPULATION AND ORDER BY THE PARTIES REGARDING 10 DAY CONTINUANCE
REGARDING PLAINTIFF’S MOTION FOR ATTORNEYS’ FEES AND COSTS
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DATED: February 12, 2015
MESERVE, MUMPER & HUGHES LLP
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/s/Linda Lawson ________
Linda Lawson
Attorneys for Defendants
THE PRUDENTIAL INSURANCE
COMPANY OF AMERICA and
PHH CORPORATION GROUP
EMPLOYEE BENEFIT PLAN
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IT IS SO ORDERED.
DONAHUE & HORROW, LLP
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Dated: February 12, 2015
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Troy L. Nunley
United States District Judge
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Case No.:2:12-cv-01173-GEB-DAD
–3–
STIPULATION AND ORDER BY THE PARTIES REGARDING 10 DAY CONTINUANCE
REGARDING PLAINTIFF’S MOTION FOR ATTORNEYS’ FEES AND COSTS
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