Guerrero v. California Department of Corrections & Rehabilitation et al

Filing 280

ORDER GRANTING 279 STIPULATION ENLARGING TIME FOR SUBMISSION OF PLAINTIFF'S MOTION FOR ATTORNEY'S FEES AND BILL OF COSTS.(whalc2, COURT STAFF) (Filed on 9/30/2015)

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Christopher Ho, State Bar No. 129845
THE LEGAL AID SOCIETY –
EMPLOYMENT LAW CENTER
180 Montgomery Street, Suite 600
San Francisco, California 94104
Telephone: [phone]
Facsimile: [phone]
E-mail: [e-mail]
Attorneys for Plaintiff
VICTOR GUERRERO

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IN THE UNITED STATES DISTRICT COURT

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FOR THE NORTHERN DISTRICT OF CALIFORNIA

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VICTOR GUERRERO,

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Plaintiff,

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v.
CALIFORNIA DEPARTMENT OF
CORRECTIONS AND REHABILITATION;
STATE PERSONNEL BOARD; and, in their
official capacities, JEFFREY BEARD,
Secretary of the California Department of
Corrections and Rehabilitation; SUZANNE
AMBROSE, Executive Officer of State
Personnel Board; K. CARROLL, Lieutenant;
D. SHARP, Sergeant; BARBARA
LEASHORE, Hearing Officer; C. HESTER,
Lieutenant; V. MAYOL, Lieutenant; S.
COX, Lieutenant; V. MYERS, Sergeant;
JOHN (OR JANE) DOES 1-100, all of
whose names are unknown,
Defendants.

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Case No. 3:13-cv-05671-WHA
STIPULATION AND [PROPOSED]
ORDER ENLARGING TIME FOR
SUBMISSION OF PLAINTIFF’S
MOTION FOR ATTORNEYS’ FEES AND
BILL OF COSTS
[Civ. L.R. 6-2]
[Hon. William Alsup]

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{00450234.DOCX}

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[3:13-cv-05671-WHA]

STIPULATION AND [PROPOSED] ORDER ENLARGING TIME FOR SUBMISSION OF
PLAINTIFF’S MOTION FOR ATTORNEYS’ FEES AND BILL OF COSTS

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As the Court entered judgment in this matter on September 28, 2015, Plaintiff currently

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has 13 days, or until October 12, 2015, by which to file a motion for attorneys’ fees and a bill of

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costs relating to his litigation expenses pursuant to Fed.R.Civ.P. 54(d) and Civ. L.R. 54-1 and

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54-5. The parties to this matter hereby stipulate pursuant to Local Rule 6-2, however, that the

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Plaintiff may have additional time, up until and including October 30, 2015, by which to file the

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two aforementioned matters. The proposed enlargement of time will permit the parties an

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adequate opportunity to meet and confer in an effort to resolve the fees and costs matters without

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the need for the Court’s involvement. A declaration to this effect is filed herewith.

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In the event that the parties are unable to informally resolve those matters, the parties

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further request that Defendants have 21 days, or until November 20, 2015 to file their

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oppositions, and that in view of the Thanksgiving holiday, Plaintiff have until December 3, 2015

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to file his replies. The parties further request that the hearing on both matters be set for

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December 17, 2015.

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A proposed order is lodged herewith.

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Dated: September 29, 2015

Respectfully submitted,

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Christopher Ho
THE LEGAL AID SOCIETY –
EMPLOYMENT LAW CENTER

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By:

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Attorneys for Plaintiff
VICTOR GUERRERO

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____________/s/________________________
CHRISTOPHER HO

Dated: September 29, 2015

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Miguel A. Neri
Fiel D. Tigno
Christopher M. Young

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{00450234.DOCX}

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[3:13-cv-05671-WHA]

STIPULATION AND [PROPOSED] ORDER ENLARGING TIME FOR SUBMISSION OF
PLAINTIFF’S MOTION FOR ATTORNEYS’ FEES

By:

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____________/s/________________________
MIGUEL A. NERI

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Attorneys for Defendant CDCR and Individual
CDCR Defendants

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Dated: September 29, 2015

Alvin Gittisriboongul
Dorothy Bacskai Egel

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By:

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____________/s/________________________
DOROTHY BACSKAI EGEL
Attorneys for Defendant SPB and Individual SPB
Defendants

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{00450234.DOCX}

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[3:13-cv-05671-WHA]

STIPULATION AND [PROPOSED] ORDER ENLARGING TIME FOR SUBMISSION OF
PLAINTIFF’S MOTION FOR ATTORNEYS’ FEES

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[PROPOSED] ORDER

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Good cause appearing, the stipulation of the parties is approved. Plaintiff may file his
motion for attorneys’ fees and bill of costs in this matter by no later than October 30, 2015.
Defendants shall have until November 20, 2015 to file their oppositions thereto. Plaintiff’s reply
briefs will be due on December 3, 2015. The hearing on both matters will be set for December
17, 2015, at _____ __.m.
8:00 a
SO ORDERED.

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Dated:_____________________
September 30, 2015.

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______________________________________
WILLIAM ALSUP
UNITED STATES DISTRICT JUDGE

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{00450234.DOCX}

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[3:13-cv-05671-WHA]

STIPULATION AND [PROPOSED] ORDER ENLARGING TIME FOR SUBMISSION OF
PLAINTIFF’S MOTION FOR ATTORNEYS’ FEES