Nunez v. Pacific Gas & Electric Retirement Plan

Filing 72

STIPULATION AND ORDER re 70 STIPULATION WITH PROPOSED ORDER Stipulation to 21-Day Enlargement if Time to File a Fee Petition, and [proposed] Order filed by Adriana Vanessa Nunez. Signed by Judge Jon S. Tigar on February 21, 2018. (wsn, COURT STAFF) (Filed on 2/21/2018)

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CREITZ & SEREBIN LLP
Joseph A. Creitz (SBN 169552)
[e-mail]
Lisa S. Serebin (SBN 146312)
[e-mail]
100 Pine St., Ste. 1250
San Francisco, CA 94111
415.466.3090 (tel)
415.513.4475 (fax)
Attorneys for Interpleader Defendant
ADRIANA VANESSA NUÑEZ

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UNITED STATES DISTRICT COURT

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FOR THE NORTHERN DISTRICT OF CALIFORNIA

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SAN FRANCISCO DIVISION

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GLORIA NUNEZ,

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Plaintiff,

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v.
PACIFIC GAS AND ELECTRIC
COMPANY RETIREMENT PLAN,

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Defendant.
[proposed] ORDER
PACIFIC GAS AND ELECTRIC
COMPANY RETIREMENT PLAN,

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STIPULATED REQUEST FOR A
21-DAY ENLARGEMENT OF TIME
FOR ADRIANNA VANESSA NUÑEZ
TO FILE A FEE PETITION
(Dkt. 67, L.R. Civ. 6-3)
and

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Case No. 3:16-cv-07412-JST

Counterclaim/Interpleader-Plaintiff,
v.

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GLORIA NUNEZ, and ADRIANA
VANESSA NUÑEZ,

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Interpleader Defendants.

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Nunez v. PG&E Retirement Plan, Case No. 16-cv-07412-JST
Stipulation to Enlargement of Time to File Fee Petition, and [proposed] ORDER

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Pursuant to Civil Local Rule 6-3, the undersigned counsel for Interpleader

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Defendant Adrianna Vanessa Nuñez, and Plaintiff and Interpleader Defendant Gloria

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Nuñez, hereby stipulate and agree as follows:
(1) Pursuant to the Court’s Order of February 12, 2018 (Dkt. 67), Interpleader

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Defendant Adrianna Vanessa Nuñez must file a fee petition, if any, no later than March

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5, 2018.

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(2) The undersigned counsel for Interpleader Defendant Adrianna Vanessa Nuñez

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is serving as first-chair in a jury trial that commences Friday February 23, 2018, and runs

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through March 9, 2018, at the earliest. The case is Kanellakopoulos v. Unimerica Life Insurance

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Co., No. 15-cv-4674-BLF, proceeding before the Honorable District Judge Beth Freeman

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in San Jose.
(3) Because of the time demands of the trial and trial preparation, it will not be

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feasible for counsel to Adriana Vanessa Nuñez to generate a fee petition by the March 5,

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2018 date currently prescribed by the Court’s Order (Dkt. 67).

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(5) There are no prior requests by the parties to enlarge time.

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(6) Granting the instant Stipulation to enlarge the due date for a fee petition will

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not affect any other date currently prescribed by the Court.

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Nunez v. PG&E Retirement Plan, Case No. 16-cv-07412-JST
Stipulation to Enlargement of Time to File Fee Petition, and [proposed] ORDER

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WHEREFORE, the undersigned hereby stipulate and agree that the deadline for

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Interpleader Defendant Adrianna Vanessa Nuñez to file a fee petition, currently

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prescribed by the Court’s Order of February 12, 2018 (Dkt. 67) shall be enlarged by

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twenty-one days, to and including March 26, 2018.

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Dated: February 20, 2018

CREITZ & SEREBIN LLP

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By: /s/ Joseph A. Creitz
Attorneys for Interpleader Defendant
ADRIANA VANESSA NUÑEZ

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Dated: February 20, 2018

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IBARRA PROFESSIONAL LAW
CORPORATION
By: /s/ Gener Benitez
Gener Benitez
Attorneys for Plaintiff and Interpleader
Defendant GLORIA NUÑEZ

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SIGNATURE ATTESTATION

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I hereby attest that I obtained the consent of all signatories hereto to the filing of
this document.
Dated: February 20, 2018

CREITZ & SEREBIN LLP

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By: /s/ Joseph A. Creitz
Attorneys for Interpleader Defendant
ADRIANA VANESSA NUÑEZ

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Nunez v. PG&E Retirement Plan, Case No. 16-cv-07412-JST
Stipulation to Enlargement of Time to File Fee Petition, and [proposed] ORDER

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[proposed] ORDER

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Pursuant to the stipulation of the parties, and good cause appearing, the deadline

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for Interpleader Defendant Adrianna Vanessa Nuñez to file a fee petition, if any, shall be

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enlarged by twenty-one days, to and including March 26, 2018.

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IT IS SO ORDERED

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Dated: February 21 , 2018

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UNITED STATES DISTRICT JUDGE

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Nunez v. PG&E Retirement Plan, Case No. 16-cv-07412-JST
Stipulation to Enlargement of Time to File Fee Petition, and [proposed] ORDER

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