Davis v. Prison Health Services, Inc. et al

Filing 211

ORDER granting extension (tf, COURT STAFF) (Filed on 1/5/2012)

Case3:09-cv-02629-SI Document204 Filed12/29/11 Page1 of 3

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PAMELA Y. PRICE, ESQ. (STATE BAR NO. 107713)
PRICE AND ASSOCIATES
A Professional Law Corporation
901 Clay Street
Oakland, CA 94607
Telephone: [phone]
Facsimile: [phone]
E-mail: [e-mail]

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FANIA E. DAVIS, ESQ. (STATE BAR NO. 87268)
4100 Redwood Road, Suite 371
Oakland, CA 94109
Telephone: [phone]
Facsimile: [phone]
E-mail: [e-mail]
DARRYL PARKER, ESQ. (STATE BAR NO. 95914)
PREMIER LAW GROUP
3131 Elliott Avenue, Suite 710
Seattle, WA 98121
Telephone: [phone]
Facsimile: [phone]
E-mail: [e-mail]
Attorneys for Plaintiff
FREDDIE M. DAVIS

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UNITED STATES DISTRICT COURT

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NORTHERN DISTRICT OF CALIFORNIA

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FREDDIE M. DAVIS,

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Plaintiff,
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v.
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PRISON HEALTH SERVICES, INC.;
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SHERIFF’S DEPARTMENT, COUNTY OF )
ALAMEDA; LEONORE GILBERT, In Her )
Individual And Official Capacities; LINDA
)
HENSON, In Her Individual And Official
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Capacities; BILL WILSON, In His Individual )
And Official Capacities; JAMES E. AYALA, )
In His Individual And Official Capacities;
)
DARRYL GRIFFITH, In His Individual And )
Official Capacities And DOES 1 through 10, )
inclusive,
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Defendants.
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NO. C09-02629 SI
STIPULATION TO EXTEND TIME FOR
PLAINTIFF’S MOTION FOR
ATTORNEYS’ FEES AND NONSTATUTORY COSTS
[Civil Local Rule 6-2]
HON. SUSAN ILLSTON

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1169ATF300PYP

-1STIPULATION TO EXTEND TIME (C09-02629 SI)

Case3:09-cv-02629-SI Document204 Filed12/29/11 Page2 of 3

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WHEREAS, pursuant to Civil Local Rule 6-2, Plaintiff FREDDIE M. DAVIS and

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Defendants JAMES E. AYALA and DARRYL GRIFFITH (collectively referred to hereinafter as

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“the Parties”) agree to extend the time for Plaintiff FREDDIE M. DAVIS to file her motion for

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attorneys’ fees and non-statutory costs pursuant to 42 U.S.C. Section 1988 up to and including

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January 24, 2012;

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WHEREAS, the Parties agree that good cause exists for this Stipulation because of the

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sheer volume of this litigation which has spanned a four-year period. Over this litigation, extensive

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written and deposition discovery was conducted. There was a voluminous dispositive motion for

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summary judgement, a litany of pretrial motions, and an eighteen (18) day trial. The Parties agree

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that it would be impossible for Ms. Davis to prepare and file a motion that encompasses a full and

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accurate appraisal of the attorneys fees and non-statutory costs that she is entitled to claim as a

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prevailing party to this matter within the fourteen (14) day time frame provided by FRCP 54(d);

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WHEREAS, in the interests of justice, and for good cause, the Parties agree to extend the

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time for Ms. Davis to file her motion in light of the sixty (60) day extension the Court has recently

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granted Defendant Griffith to file his motion for attorneys’ fees (Docket # 203); and

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WHEREAS, the Parties agree that the aforementioned extension will not affect any

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scheduling for this case, IT IS HEREBY STIPULATED AND AGREED by the Parties, through

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their respective attorneys of record, that Plaintiff FREDDIE M. DAVIS shall have an extension to

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and including January 24, 2012 to file her motion for attorneys’ fees and non-statutory costs. It is

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hereby understood that Defendants reserve any and all rights to oppose any and all aspects of said

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motion(s).

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Dated: December 29, 2011

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/s/ Pamela Y . Price
PAMELA Y. PRICE, Attorneys for Plaintiff
FREDDIE M. DAVIS

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1169ATF300PYP

PRICE AND ASSOCIATES

Dated: December 29, 2011

ANDRADA & ASSOCIATES
/s/ Lynne G. Stocker
LYNNE G. STOCKER, Attorneys for Defendants
COUNTY OF ALAMEDA, JAMES E. AYALA,
And DARRYL GRIFFITH

-2STIPULATION TO EXTEND TIME (C09-02629 SI)

Case3:09-cv-02629-SI Document204 Filed12/29/11 Page3 of 3

ORDER

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The Court having read and considered the foregoing Stipulation of the parties,

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and good cause appearing therefore, IT IS HEREBY ORDERED that the time for filing Plaintiff’s

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Motion for attorneys’ fees and non-statutory costs pursuant to 42 U.S.C. Section 1988 shall be and

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hereby is enlarged to January 24, 2012.
IT IS SO ORDERED.

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1/5/12
Dated: ________________

__________________________________________
HON. SUSAN ILLSTON
UNITED STATES DISTRICT COURT

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1169ATF300PYP

-3STIPULATION TO EXTEND TIME (C09-02629 SI)