Sassman v. Brown et al

Filing 98

ORDER signed by Chief Judge Morrison C. England, Jr on 11/30/2015 ORDERING 97 that the deadline for Plaintiff to file his application for attorneys' fees and costs is hereby EXTENDED up to and including 1/11/2016. (Reader, L)

1 GAY CROSTHWAIT GRUNFELD – 121944
BLAKE THOMPSON – 255600
2 VAN SWEARINGEN – 259809
ROSEN BIEN GALVAN & GRUNFELD LLP
3 50 Fremont Street, 19th Floor
San Francisco, California 94105-2235
4 Telephone: [phone]
Facsimile: [phone]
[e-mail]
5 Email:
[e-mail]
[e-mail]
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7 CAROL STRICKMAN – 078341
LEGAL SERVICES FOR PRISONERS WITH CHILDREN
8 1540 Market Street, Suite 490
San Francisco, California 94102
9 Telephone: [phone]
Facsimile: [phone]
[e-mail]
10 Email:
11 Attorneys for Plaintiff
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UNITED STATES DISTRICT COURT

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EASTERN DISTRICT OF CALIFORNIA

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SACRAMENTO DIVISION

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17 WILLIAM A. SASSMAN,
Plaintiff,

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v.

20 EDMUND G. BROWN, JR. Governor of
California, and JEFFREY A. BEARD,
21 Secretary of the California Department of
Corrections and Rehabilitation, in their
22 official capacities, and DOES 1-10,
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Case No. 2:14-cv-01679-MCE-KJN
STIPULATION AND ORDER FOR
EXTENSION OF TIME TO FILE FEE
APPLICATION
Judge: Hon. Morrison C. England, Jr.
Crtrm: 7, 14th Floor
Trial Date:

None Set

Defendants.

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[2890361-1]

2:14-cv-01679-MCE-KJN
STIPULATION AND ORDER FOR EXTENSION OF TIME TO FILE FEE APPLICATION

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WHEREAS, the Court entered its Memorandum and Order (Dkt. No. 77) granting

2 summary judgment for Plaintiff William Sassman (“Plaintiff”) on September 9, 2015, and
3 issued a Judgment (Dkt. No. 78) in favor of Plaintiff on that same date; and
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WHEREAS, on September 28, 2015, per the parties’ stipulation, the Court ordered

5 that the deadline for Plaintiff to file his application for attorneys’ fees and costs be set for
6 December 4, 2015 (Dkt No. 82);
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WHEREAS, the parties have begun negotiations regarding a potential settlement of

8 Plaintiffs’ attorneys’ fees and costs, which could obviate the need for the Court to
9 adjudicate a fee motion in this case. However, the parties do not believe that the
10 December 4, 2015 deadline will provide sufficient time for a formal resolution to be
11 reached to avoid the need for Plaintiff to prepare his application; and
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WHEREAS, the parties to the above-captioned case, through their counsel of

13 record, have therefore agreed to a short extension of the time to submit an application for
14 attorneys’ fees and costs, in an effort to attempt to resolve this matter without the need for
15 a fee application to the Court;
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NOW, THEREFORE, IT IS HEREBY STIPULATED AND AGREED, by and

17 between the parties, through their counsel of record, that Plaintiff shall have an extension
18 of time up to and including January 11, 2016, in which to submit an application for
19 attorneys’ fees and costs. By entering into this stipulation, Defendants do not waive their
20 right to appeal or the right to object to costs or attorneys’ fees.
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IT IS SO STIPULATED.

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23 DATED: November 19, 2015

ROSEN BIEN GALVAN & GRUNFELD LLP

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By: /s/ Gay Crosthwait Grunfeld
Gay Crosthwait Grunfeld

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Attorneys for Plaintiff

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[2890361-1]

2:14-cv-01679-MCE-KJN
1
STIPULATION AND ORDER FOR EXTENSION OF TIME TO FILE FEE APPLICATION

1 DATED: November 19, 2015
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KAMALA D. HARRIS
Attorney General of California
By: /s/ Martine N. D’Agostino
Martine N. D’Agostino
Deputy Attorney General

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Attorneys for Defendants
Edmund G. Brown Jr. and Jeffrey A. Beard, Ph.D.

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ORDER
The Court, having reviewed the above stipulation of the parties, and good cause

10 appearing, hereby orders that the deadline for Plaintiff to file his application for attorneys’
11 fees and costs is hereby extended up to and including January 11, 2016.
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IT IS SO ORDERED.

13 Dated: November 30, 2015
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[2890361-1]

2:14-cv-01679-MCE-KJN
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STIPULATION AND ORDER FOR EXTENSION OF TIME TO FILE FEE APPLICATION