Opinion
Case No. C 11-02267 DMR
03-25-2013
GONZALES & GONZALES BONDS AND INSURANCE AGENCY, INC., Plaintiff, v. UNITED STATES DEPARTMENT OF HOMELAND SECURITY, Defendant.
Gary A. Nye, Esq. (Cal. Bar No. 126104) David R. Ginsburg, Esq. (Cal. Bar No. 210900) ROXBOROUGH, POMERANCE, NYE & ADREANI, LLP 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 Attorneys for Defendant United States Department of Homeland Security
Gary A. Nye, Esq. (Cal. Bar No. 126104)
David R. Ginsburg, Esq. (Cal. Bar No. 210900)
ROXBOROUGH, POMERANCE, NYE & ADREANI, LLP
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
Attorneys for Defendant
United States Department of Homeland Security
Honorable Donna M. Ryu
STIPULATION AND [PROPOSED]
ORDER EXTENDING THE DEADLINE
FOR PLAINTIFF TO FILE MOTION FOR
ATTORNEY'S FEES AND BILL OF
COSTS
Plaintiff Gonzales & Gonzales Bonds and Insurance Agency, Inc. ("G&G" or "Plaintiff') and Defendant United States Department of Homeland Security ("DHS"), by and through their respective counsel, make the following representations and stipulate and agree as follows:
G&G and DHS are continuing to engage in meaningful meet and confer discussions regarding G&G's motion for attorney's fees and bill of costs based on the Court's Order of December 21, 2012, which ruled upon the parties' motions for summary judgment in this Freedom of Information Act case. The most recent discussion occurred on March 21, 2013, and the parties expect to continue discussions over the next couple weeks. The parties' mutual goal is to resolve the fee and cost issue without the need for motion work and a hearing on the matter; however, the negotiations are taking more time than the parties anticipated.
The current filing deadline for the motion and bill of costs is April 2, 2013. Based on their most recent meet and confer, the parties agree that an extension to May 15, 2013 would allow for further meaningful discussion. The parties therefore respectfully request that the Court approve this requested extension.
This is the fifth requested extension of the original January 4, 2013 deadline.
DHS' deadline for filing opposition to G&G's motion for attorney's fees and bill of costs would continue to be 30 days from the filing of G&G's motion and bill of costs.
The requested extension would not affect the schedule for the case.
Nothing herein shall constitute a waiver of DHS' right to oppose or object to G&G's motion for attorney's fees and bill of costs.
Respectfully submitted,
ROXBOROUGH, POMERANCE, NYE & ADREANI, LLP
David R. Ginsburg
Gary A. Nye
David R. Ginsburg
Attorneys for Plaintiff
Gonzales & Gonzales Bonds and Insurance
Agency, Inc.
Respectfully submitted,
MELINDA HAAG
United States Attorney
______________________
ANN MARIE REDING
Assistant United States Attorney
Attorneys for Defendant
Department of Homeland Security
[PROPOSED] ORDER
Pursuant to the stipulation by the parties, the Court extends from April 2, 2013 to May 15, 2013, the deadline for G&G to file its motion for attorney's fees and its bill of costs. DHS' deadline to file opposition to G&G's motion for attorney's fees and bill of costs will remain 30 days from the filing of G&G's motion and bill of costs.
IT IS SO ORDERED.
______________________
THE HONORABLE DONNA M. RYU
UNITED STATES MAGISTRATE JUDGE