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

Filing 73

Order by Magistrate Judge Donna M. Ryu granting 72 Stipulation.(dmrlc2S, COURT STAFF) (Filed on 3/25/2013)

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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
Case No. C 11-02267 DMR
GONZALES & GONZALES BONDS
AND INSURANCE AGENCY, INC.,
Honorable Donna M. Ryu
Plaintiff,
STIPULATION AND [PROPOSED]
vs.
ORDER EXTENDING THE DEADLINE
FOR PLAINTIFF TO FILE MOTION FOR
UNITED STATES DEPARTMENT OF
ATTORNEY’S FEES AND BILL OF
HOMELAND SECURITY,
COSTS

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Defendant.

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STIPULATION AND ORDER

Case No. C 11-02267 DMR

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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 21, 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; however, the negotiations are taking more time than the parties anticipated.

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The current filing deadline for the motion and bill of costs is April 2, 2013. Based on

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their most recent meet and confer, the parties agree that an extension to May 15, 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 fifth 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

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Dated: March 22, 2013

Respectfully submitted,
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 22, 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

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[PROPOSED] ORDER
Pursuant to the stipulation by the parties, the Court extends from April 2, 2013 to May

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15, 2013, the deadline for G&G to file its motion for attorney’s fees and its bill of costs. DHS’

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deadline to file opposition to G&G’s motion for attorney’s fees and bill of costs will remain 30

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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 25, 2013
____________________________________
THE HONORABLE DONNA M. RYU
UNITED STATES MAGISTRATE JUDGE

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STIPULATION AND ORDER

Case No. C 11-02267 DMR