Griffin v. Gomez, et al

Filing 171

STIPULATION AND ORDER Extending Time to File Bill of Costs re 169 Stipulation. Signed by Judge James Ware on 7/29/2009. (ecg, COURT STAFF) (Filed on 8/4/2009)

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UNIT ED S S DISTRICT TE C TA 1 2 3 4 5 6 ROBERT LEE GRIFFIN 7 Petitioner, 8 9 10 11 12 13 14 15 DATED: July 24, 2009 16 17 18 19 20 21 22 23 24 25 26 27 28 and JAMES GOMEZ, ET AL Respondent. ) ) ) ) ) ) ) ) ) N No. C 98-21038 JW F D IS T IC T O R STIPULATED REQUEST FOR ORDER CHANGING TIME For the reasons set forth in the attached Declaration, the parties stipulate to and request postponement of the time for filing by petitioner of a Bill of Costs to a date 14 days following completion of all additional filings and/or proceedings requested by the Court pursuant to its July 10, 2009 Order. Respectfully Submitted, /s/ Pamela J. Griffin Pamela J. Griffin Attorney for the Petitioner /s/ Robert C. Cross Robert C. Cross Deputy Attorney General Attorneys for Respondents S tip u la te d Request for Order Changing Time 1 A es IN THE UNITED STATES DISTRICT COURTudge Jam J FOR THE NORTHERN DISTRICT OF CALIFORNIA SAN JOSE DIVISION ER C LI FO Ware R NIA O OR IT IS S DERED RT U O NO RT H 1 2 3 4 ROBERT LEE GRIFFIN 5 Petitioner, 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 S tip u la te d Request for Order Changing Time IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF CALIFORNIA SAN JOSE DIVISION ) ) ) ) ) ) ) ) ) No. C 98-21038 JW DECLARATION OF PAMELA GRIFFIN IN SUPPORT OF STIPULATED REQUEST FOR ORDER CHANGING TIME and JAMES GOMEZ, ET AL Respondent. 1. 2. I am the attorney for the Petitioner in the above-referenced case. The Petitioner intends to submit a Bill of Costs pursuant to Civil L.R. 54-1 with respect to post- judgment proceedings in this case. 3. On July 10, 2009, the Court issued its Order Adopting Magistrate Judge's Report and Recommendation; Overruling Objections to Magistrate's Report and Recommendation, in which the parties were ordered to file a status update by the end of July. The Court indicated it would then determine whether further review of Respondents' actions is appropriate. 4. Given the certainty of an additional filing and the possibility of further proceedings in this matter, allowing the petitioner to postpone submission of a Bill of Costs until all filings and proceedings are concluded would minimize potential for confusion and the inefficient use of court resources. 5. Postponement or extension of the time in which to file a Bill of Costs would not affect any existing deadline or schedule in this case, and counsel for Respondents has agreed and stipulated. I declare under penalty of perjury the foregoing is true and correct. DATED: July 24, 2009 Respectfully Submitted, /s/ Pamela J. Griffin Pamela J. Griffin Attorney for the Petitioner 2

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