Faith Center Church Evengelist Ministries et al v. Glover et al

Filing 117

STIPULATION Requesting Order to Extend Time to File Motion for Attorneys' Fees and Non-Taxable Costs by Faith Center Church Evengelist Ministries, Hattie Hopkins. (Attachments: # 1 Proposed Order)(Chandler, Timothy) (Filed on 8/14/2009)

Faith Center Church Evengelist Ministries et al v. Glover et al

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ALLIANCE DEFENSE FUND BENJAMIN W. BULL Arizona State Bar No. 009940 GARY S. McCALEB (admitted pro hac vice) Arizona State Bar No. 018848 15100 North 90th Street Scottsdale, Arizona 85260 Phone: [phone]; Fax: [phone] ALLIANCE DEFENSE FUND TIMOTHY D. CHANDLER California State Bar No. 234325 101 Parkshore Dr., Suite 100 Folsom, California 95630 Phone: [phone]; Fax: [phone] LAW OFFICES OF TERRY L. THOMPSON TERRY L. THOMPSON California State Bar No. 199870 P.O. Box 1346 Alamo, California 94507 Phone: [phone]; Fax: [phone] (designated local counsel) Attorneys for Plaintiffs COUNTY OF CONTRA COSTA THOMAS L. GEIGER California State Bar No. 199729 CYNTHIA A. SCHWERIN California State Bar No. 204198 651 Pine Street, 9th Floor Martinez, CA 94553-1228 Phone: [phone]; Fax: [phone] Attorneys for Defendants IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF CALIFORNIA FAITH CENTER CHURCH EVANGELISTIC MINISTRIES, et al., Plaintiffs, v. FEDERAL D. GLOVER, et al., CASE NO. C-04-3111 JSW STIPULATED REQUEST FOR ORDER EXTENDING TIME TO FILE MOTION FOR ATTORNEYS' FEES AND NONTAXABLE COSTS

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FAITH CENTER V. GLOVER ­ STIPULATED REQUEST FOR ORDER EXTENDING TIME­ C-04-3111 JSW

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The parties stipulate as follows: 1. On July 1, 2005, this Court signed the parties' stipulation extending the deadline for

filing a motion for attorneys' fees and non-taxable costs until 30 days after the time period for all appeals expired.1 The time period to appeal this Court's summary judgment order ended on July 20, 2009,2 meaning that Faith Center's fee motion is currently due on August 19, 2009. There have been no other time modifications in this case related to the fee motion. 2. On August 13, 2009, counsel for both parties met and conferred about Faith Center's

fee motion in an attempt to resolve any disputed issues with respect to the motion, as required by Local Rule 54-6(b)(1). 3. The parties agree there is a reasonable possibility that they will be able to resolve all

disputed issues with respect to Faith Center's fee motion. But given the length of the case, the parties need additional time to try to resolve the disputed issues on their own. Additionally, if a proposed agreement is reached as to all disputed issues, additional time is needed to allow a settlement to be approved formally by the County Board of Supervisors. 4. Accordingly, the parties respectfully request that the deadline for filing Faith Center's

fee motion be extended by three weeks, to September 9, 2009. This extension would not have any other effect on the schedule for this case.

Respectfully submitted this 14th day of August, 2009. /s/ Timothy D. Chandler____ Timothy D. Chandler Attorney for Plaintiffs By: /s/ Thomas L. Geiger____ Thomas L. Geiger Attorney for Defendants

See Notice of Withdrawal of Motion and Joint Stipulation to Change the Time for Plaintiffs' Application for Attorneys' Fees and Costs [Document #72], filed July 1, 2005.
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See Federal Rule of Appellate Procedure 4(a)(1)(A) (setting 30-day deadline for filing a notice of appeal in a civil case).

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I hereby attest that I have on file all holograph signatures for any signatures indicated by a "conformed" signature (s/) within this efiled document. By: /s/ Timothy D. Chandler____ Timothy D. Chandler Attorney for Plaintiffs

FAITH CENTER V. GLOVER ­ STIPULATED REQUEST FOR ORDER EXTENDING TIME­ C-04-3111 JSW

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