Italian Colors Restaurant, et al. v. Harris

Filing 56

STIPULATION and ORDER signed by District Judge Morrison C. England, Jr on 3/16/2018 ORDERING pursuant to Federal Rule of Civil Procedure 54, the deadline for Plaintiffs' motion for attorneys' fees, related nontaxable expenses, or costs in this action is hereby extended by 30 days to not later than April 3, 2018. (Becknal, R)

IN THE UNITED STATES DISTRICT COURT
FOR THE EASTERN DISTRICT OF CALIFORNIA

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ITALIAN COLORS RESTAURANT, ALAN
CARLSON, STONECREST GAS & WASH,
SALAM RAZUKI, LAURELWOOD
CLEANERS, LLC, JONATHAN
EBRAHIMIAN, LEON’S TRANSMISSION
SERVICE, INC., VINCENT ARCHER,
FAMILY LIFE CORPORATION d/b/a
FAMILY GRAPHICS, TOSHIO CHINO,

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Plaintiffs,

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v.

Case No.: 2:14-cv-00604-MCE-DAD
STIPULATION TO EXTENSION OF TIME
FOR ATTORNEYS’ FEES, EXPENSES,
AND COSTS; ORDER

Date:
Time:
Courtroom:

N/A
N/A
7, 14th Floor
Hon. Morrison C. England, Jr.

KAMALA D. HARRIS, in her official
capacity as Attorney General of the State of
California,

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Defendant.

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The parties hereby jointly request a 30-day extension, from March 4, 2018 to April 3,
2018, of the deadline to file any application concerning attorneys’ fees, related nontaxable
expenses, or costs.

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On May 11, 2015, this Court adopted the parties’ stipulation that any motion for
attorneys’ fees, related nontaxable expenses, or costs in this action be filed within 30 days of the
judgment of the U.S. Court of Appeals for the Ninth Circuit, the dismissal of the appeal for any
reason, or the final judgment of this Court on remand, whichever is later.

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Following the Ninth Circuit’s recent decision in this case, this Court adopted the parties’
stipulation for a 30-day extension of the deadline for a fee motion, to and including March 4,
2018.
The parties believe that the second extension requested here will allow them to discuss
settlement of the remaining attorneys’ fees issues and thereby possibly avoid unnecessary
further litigation. In addition, additional time is necessary because of the complexity of the
litigation, and because plaintiffs’ counsel have had, and will have an unusual number of
competing litigation obligations this month and in the coming month.

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Case No.: 2:14-cv-00604

STIPULATION TO EXTENSION OF TIME FOR ATTORNEYS’S FEES, EXPENSES AND COSTS

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Dated: March 2, 2018

STIPULATED AND AGREED:

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/s/ Deepak Gupta
Deepak Gupta*
Jonathan E. Taylor
GUPTA WESSLER PLLC
1900 L Street, NW, Suite 312
Washington, DC 20036
Telephone: [phone]
Facsimile: [phone]
[e-mail]

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Edward S. Zusman (SBN 154366)
Kevin K. Eng (SBN 209036)
MARKUN ZUSMAN FRENIERE
COMPTON LLP
465 California Street, Suite 500
San Francisco, CA 94104
Telephone: [phone]
Facsimile: [phone]

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Gary B. Friedman*
Tracey Kitzman
Rebecca Quinn
FRIEDMAN LAW GROUP LLP
270 Lafayette Street
New York, NY 10012
[phone]

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Howard M. Jaffe
JAFFE + MARTIN
1801 Century Park East
Suite 1600
Los Angeles, CA 90067
[phone]

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Alex M. Tomasevic
NICHOLAS & TOMASEVIC LLP
225 Broadway - 19th Floor
San Diego, CA 92101
[phone]

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Robert W. Cohen
LAW OFFICES OF ROBERT W.
COHEN
1875 Century Park East, Suite 1770
Los Angeles, CA 90067
Telephone: [phone]
Facsimile: [phone]

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*admitted pro hac vice

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Attorneys for Plaintiffs

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Case No.: 2:14-cv-00604

STIPULATION TO EXTENSION OF TIME FOR ATTORNEYS’S FEES, EXPENSES AND COSTS

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/s/ John Killeen
Xavier Becerra
Attorney General of California
John Killeen
Deputy Attorney General
Anthony R. Hakl
Deputy Attorney General
1300 I Street, Suite 125
P.O. Box 944255
Sacramento, CA 94244-2550
[phone]
[e-mail]

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Attorneys for Defendant

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Case No.: 2:14-cv-00604

STIPULATION TO EXTENSION OF TIME FOR ATTORNEYS’S FEES, EXPENSES AND COSTS

ORDER

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Upon the parties’ stipulation and good cause appearing, pursuant to Federal Rule of Civil

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Procedure 54, the deadline for Plaintiffs’ motion for attorneys’ fees, related nontaxable expenses,

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or costs in this action is hereby extended by 30 days to not later than April 3, 2018.

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IT IS SO ORDERED.

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DATED: March 16, 2018

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_______________________________________
MORRISON C. ENGLAND, JR.
UNITED STATES DISTRICT JUDGE

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Case No.: 2:14-cv-00604

STIPULATION TO EXTENSION OF TIME FOR ATTORNEYS’S FEES, EXPENSES AND COSTS

CERTIFICATE OF SERVICE

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I certify that I filed a copy of the foregoing stipulation and proposed order via the Court’s

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CM/ECF system on March 2, 2018, which will automatically serve a copy on counsel for the

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defendants.

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Dated: March 2, 2018

/s/ Deepak Gupta
Deepak Gupta

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Case No.: 2:14-cv-00604

STIPULATION TO EXTENSION OF TIME FOR ATTORNEYS’S FEES, EXPENSES AND COSTS