Gonzales & Gonzales Bonds and Insurance Agency, Inc. v. United States Department of Homeland Security

Filing 69

Order by Magistrate Judge Donna M. Ryu granting 68 Stipulation.(dmrlc2, COURT STAFF) (Filed on 3/11/2013)

Case4:11-cv-02267-DMR Document68 Filed03/09/13 Page1 of 4

1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16

Gary A. Nye, Esq. (Cal. Bar No. 126104)
David R. Ginsburg, Esq. (Cal. Bar No. 210900)
ROXBOROUGH, POMERANCE, NYE & ADREANI, LLP
5820 Canoga Avenue, Suite 250
Woodland Hills, California 91367
Telephone: [phone]
Facsimile: [phone]
Email:
[e-mail]; [e-mail]
Attorneys for Plaintiff
Gonzales & Gonzales Bonds and Insurance Agency, Inc.
MELINDA HAAG (CSBN 132612)
United States Attorney
ALEX G. TSE (CSBN 152348)
Chief, Civil Division
ANN MARIE REDING (CSBN 226864)
Assistant United States Attorney
450 Golden Gate Avenue, Box 36055
San Francisco, California 94102-3495
Telephone: [phone]
Fax: [phone]
Email: [e-mail]
Attorneys for Defendant
United States Department of Homeland Security

17

UNITED STATES DISTRICT COURT

18

NORTHERN DISTRICT OF CALIFORNIA - OAKLAND DIVISION

19
20

GONZALES & GONZALES BONDS
AND INSURANCE AGENCY, INC.,
Plaintiff,

21
22

vs.

23

UNITED STATES DEPARTMENT OF
HOMELAND SECURITY,

24
25

Case No. C 11-02267 DMR
Honorable Donna M. Ryu
STIPULATION AND [PROPOSED]
ORDER EXTENDING THE DEADLINE
FOR PLAINTIFF TO FILE MOTION FOR
ATTORNEY’S FEES AND BILL OF
COSTS

Defendant.

26
27
28

STIPULATION AND ORDER

Case No. C 11-02267 DMR

Case4:11-cv-02267-DMR Document68 Filed03/09/13 Page2 of 4

1

Plaintiff Gonzales & Gonzales Bonds and Insurance Agency, Inc. (“G&G” or

2

“Plaintiff”) and Defendant United States Department of Homeland Security (“DHS”), by and

3

through their respective counsel, make the following representations and stipulate and agree as

4

follows:

5

G&G and DHS are continuing to engage in meet and confer efforts regarding G&G’s

6

motion for attorney’s fees and bill of costs based on the Court’s Order of December 21, 2012,

7

which ruled upon the parties’ motions for summary judgment in this Freedom of Information

8

Act case.

9

The current filing deadline for the motion and bill of costs is March 12, 2013. The

10

parties seek to extend this deadline by one week, to March 19, 2013, to allow for additional

11

time to meet and confer. The parties respectfully request that the Court approve this requested

12

extension.

13

This is the third requested extension of the original January 4, 2013 deadline.

14

DHS’ deadline for filing opposition to G&G’s motion for attorney’s fees and bill of costs

15

would continue to be 30 days from the filing of G&G’s motion and bill of costs.

16

The requested extension would not affect the schedule for the case.

17

Nothing herein shall constitute a waiver of DHS’ right to oppose or object to G&G’s

18

motion for attorney’s fees and bill of costs.

19
20
21
22
23
24
25
26
27
28

1
STIPULATION AND ORDER

Case No. C 11-02267 DMR

Case4:11-cv-02267-DMR Document68 Filed03/09/13 Page3 of 4

1
2

Respectfully submitted,
Dated: March 8, 2013

3

ROXBOROUGH, POMERANCE, NYE & ADREANI, LLP
/s/ David R. Ginsburg
Gary A. Nye
David R. Ginsburg
Attorneys for Plaintiff
Gonzales & Gonzales Bonds and Insurance
Agency, Inc.

4
5
6
7
8
9

Dated: March 8, 2013

10

Respectfully submitted,
MELINDA HAAG
United States Attorney
/s/ Ann Marie Reding
ANN MARIE REDING
Assistant United States Attorney
Attorneys for Defendant
Department of Homeland Security

11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28

2
STIPULATION AND ORDER

Case No. C 11-02267 DMR

Case4:11-cv-02267-DMR Document68 Filed03/09/13 Page4 of 4

1
2

[PROPOSED] ORDER
Pursuant to the stipulation by the parties, the Court extends from March 12, 2013 to

3

March 19, 2013, the deadline for G&G to file its motion for attorney’s fees and its bill of costs.

4

DHS’ deadline to file opposition to G&G’s motion for attorney’s fees and bill of costs will

5

remain 30 days from the filing of G&G’s motion and bill of costs.

6
7
8

IT IS SO ORDERED.

9
10
11
12

Dated: March 11, 2013

13
14

____________________________________
THE HONORABLE DONNA M. RYU
UNITED STATES MAGISTRATE JUDGE

15
16
17
18
19
20
21
22
23
24
25
26
27
28

3
STIPULATION AND ORDER

Case No. C 11-02267 DMR