Opinion
CASE NO. 1:10-cv-02018-AWI-GSA
02-25-2013
GENEVA LEMA, Plaintiff, v. MODESTO HOSPITALITY, LLC; and DOES 1 THROUGH 50, Inclusive, Defendants.
Thimesch Law Offices TIMOTHY S. THIMESCH, ESQ. 148213 Attorneys for Plaintiff GENEVA LEMA GARY R. BASHAM (Bar No. 130119) AARON R. JACKSON (Bar No. 233816) BASHAM LAW GROUP Attorneys for Defendant MODESTO HOSPITALITY
Thimesch Law Offices
TIMOTHY S. THIMESCH, ESQ. 148213
Attorneys for Plaintiff GENEVA LEMA GARY R. BASHAM (Bar No. 130119)
AARON R. JACKSON (Bar No. 233816)
BASHAM LAW GROUP
Attorneys for Defendant MODESTO HOSPITALITY
Civil Rights
STIPULATION AND ORDER EXTENDING
THE TIME FOR PLAINTIFF TO MOVE
FOR AN AWARD OF REASONABLE
STATUTORY ATTORNEY'S FEES,
LITIGATION EXPENSES AND COSTS
TO THE COURT:
This is a request to extend the time provided under ¶26 of the December 18, 2012 Consent Decree Order and Judgment, which provides 65 days for Plaintiff to file a motion for an award of reasonable statutory attorney's fees, litigation expenses and costs. In this regard, the Consent Decree also required the parties to make a good faith effort to settle the matter short of a motion (§27), and the parties are presently continuing such efforts. They are in the process of scheduling a mediation before Stephen Schrey, Esq. of San Francisco. To allow this process to complete while avoiding the potentially unnecessary expense of bringing and opposing a motion, the parties request that the Court extend the deadline by an additional 45 days to April 7, 2013.
SO STIPULATED.
TIMOTHY S. THIMESCH
THIMESCH LAW OFFICE
By: ___________________________
Attorneys for Plaintiff
GENEVA LEMA
BASHAM LAW GROUP
By: ___________________________
GARY R. BASHAM
AARON R. JACKSON
Attorneys for Defendant
MODESTO HOSPITALITY LLC
ORDER
IT IS SO ORDERED.
________________________
SENIOR DISTRICT JUDGE