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

Filing 71

Order by Magistrate Judge Donna M. Ryu granting 70 Stipulation.(dmrlc2, COURT STAFF) (Filed on 3/13/2013)

Case4:11-cv-02267-DMR Document70 Filed03/13/13 Page1 of 4

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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

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UNITED STATES DISTRICT COURT

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NORTHERN DISTRICT OF CALIFORNIA - OAKLAND DIVISION

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

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vs.

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UNITED STATES DEPARTMENT OF
HOMELAND SECURITY,

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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.

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STIPULATION AND ORDER

Case No. C 11-02267 DMR

Case4:11-cv-02267-DMR Document70 Filed03/13/13 Page2 of 4

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

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

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

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follows:

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G&G and DHS are continuing to engage in meaningful meet and confer discussions

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regarding G&G’s motion for attorney’s fees and bill of costs based on the Court’s Order of

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December 21, 2012, which ruled upon the parties’ motions for summary judgment in this

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Freedom of Information Act case. The most recent discussion occurred on March 12, 2013,

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and the parties expect to continue discussions over the next couple weeks. The parties’ mutual

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goal is to resolve the fee and cost issue without the need for motion work and a hearing on the

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matter.

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The current filing deadline for the motion and bill of costs is March 19, 2013. Based

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on their most recent meet and confer, the parties agree that an extension to April 2, 2013 would

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allow for further meaningful discussion. The parties therefore respectfully request that the

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Court approve this requested extension.

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

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

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

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

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

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motion for attorney’s fees and bill of costs.

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STIPULATION AND ORDER

Case No. C 11-02267 DMR

Case4:11-cv-02267-DMR Document70 Filed03/13/13 Page3 of 4

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Respectfully submitted,
Dated: March 13, 2013

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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.

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Dated: March 13, 2013

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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

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STIPULATION AND ORDER

Case No. C 11-02267 DMR

Case4:11-cv-02267-DMR Document70 Filed03/13/13 Page4 of 4

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[PROPOSED] ORDER
Pursuant to the stipulation by the parties, the Court extends from March 19, 2013 to

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April 2, 2013, the deadline for G&G to file its motion for attorney’s fees and its bill of costs.

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

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

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IT IS SO ORDERED.

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Dated: March 13, 2013

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____________________________________
THE HONORABLE DONNA M. RYU
UNITED STATES MAGISTRATE JUDGE

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STIPULATION AND ORDER

Case No. C 11-02267 DMR