Woodford et al v. Sav-on-Gasoline

Filing 16

STIPULATION AND ORDER CONTINUING DATE FOR FILING OF PLAINTIFF'S MOTION FOR AWARD OF ATTORNEYS' FEES, LITIGATION EXPENSES AND COSTS re 15 Proposed Order filed by Zachary T Woodford. Signed by Judge Patricia V. Trumbull on April 8, 2010. (pvtlc2, COURT STAFF) (Filed on 4/8/2010)

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PAUL L. REIN, Esq. (SBN 43053) CELIA MCGUINNESS, Esq. (SBN 159420) LAW OFFICES OF PAUL L. REIN 200 Lakeside Drive, Suite A Oakland, CA 94612 Telephone: [phone] Facsimile: 510/832-4787 Attorneys for Plaintiff ZACHARY T. WOODFORD IN THE UNITED STATES DISTRICT COURT IN AND FOR THE NORTHERN DISTRICT OF CALIFORNIA ZACHARY T. WOODFORD, Plaintiff, v. CASE NO. 09-00443 PVT Civil Rights
XXXXXXXXXXXXX STIPULATION AND [PROPOSED]XXXX ORDER CONTINUING DATE FOR FILING OF PLAINTIFF'S MOTION FOR AWARD OF ATTORNEY FEES, LITIGATION EXPENSES AND COSTS

SAV-ON GASOLINE; ABBAS ALI NAZEMI dba SAV-ON 14 GASOLINE; AND DOES 1-10, INCLUSIVE,
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L A W O F F IC E S O F

Defendants.

/ STIPULATION

The Consent Decree specifying injunctive relief and payment of damages was previously entered by the Court, and a date was set for plaintiff to file a motion for attorney fees. Pursuant to an earlier stipulation by the parties, the Court previously granted an Order for an extension of time to April 9, 2010, for plaintiff to file an attorney fees motion. The parties now respectfully request that the Court grant an additional extension of time for such motion. Defense counsel has represented that defendants do not have any insurance coverage, and the parties are continuing to attempt to work out an agreement that will allow them to stipulate to certain issues, and thus relieve the Court from the necessity of adjudicating a fully contested fee motion. Accordingly, plaintiff Zachary Woodford and all defendants in the
SECOND STIPULATION AND [PROPOSED] ORDER CONTINUING DATE FOR FILING ATTORNEY'S FEES MOTION CASE NO. 09-00443 PVT

PAUL L. REIN
200 L A K E S I D E D R ., S U I T E A O A K L A N D , C A 94612-3503 [phone]

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L A W O F F IC E S O F

above-captioned action stipulate that the April 9, 2010 deadline previously specified for plaintiff's motion for attorney fees be extended by forty-nine (49) days to May 28, 2010, so that the parties my settle this issue by negotiation, or agree on certain issues to simplify the elements of any fee motion which will be presented to the Court by plaintiff. Therefore IT IS HEREBY STIPULATED BETWEEN the parties that the deadline for plaintiff to make his fees motion to the Court be extended to May 28, 2010 . Dated: April 6, 2010 LAW OFFICES OF PAUL L. REIN /s/ Paul L. Rein By PAUL L. REIN Attorneys for Plaintiff ZACHARY T. WOODFORD Dated: April 6, 2010 BASKIN & GRANT, LLP /s/ Caleb Baskin By Caleb Baskin, Esq. Attorneys for Defendants SAV-ON GASOLINE and ABBAS ALI NAZEMI dba SAV-ON GASOLINE

ORDER Pursuant to stipulation, and for good cause shown, IT IS SO ORDERED. The deadline for plaintiff to make his fees motion to the Court shall be extended to May 28, 2010 .
8 Dated: April __, 2010

__________________________ HON. PATRICIA V. TRUMBULL U.S. MAGISTRATE JUDGE
SECOND STIPULATION AND [PROPOSED] ORDER CONTINUING DATE FOR FILING ATTORNEY'S FEES MOTION CASE NO. 09-00443 PVT

PAUL L. REIN
200 L A K E S I D E D R ., S U I T E A O A K L A N D , C A 94612-3503 [phone]

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S :\C A S E S \S \S A V -O N GAS\PLEADINGS\STIP RE ATTY FEES MOTION.PL2.wpd