Opinion
No. C08-3988 EMC
11-08-2011
ANURAG TIWARI, Plaintiff, v. NBC UNIVERSAL, INC., Defendant.
Thomas R. Burke Attorneys for Defendant NBCUniversal Media, LLC Elizabeth Pritzker Attorneys for Plaintiff Anurag Tiwari
THOMAS R .BURKE (CA State Bar No. 141930)
JEFF GLASSER (CA State Bar No. 252596)
DAVIS WRIGHT TREMAINE LLP
Attorneys for Defendant NBCUniversal Media, LLC
STIPULATION TO EXTEND TIME
FOR DEFENDANT NBCUNIVERSAL
MEDIA, LLC'S MOTION TO
RECOVER ATTORNEYS' FEES AND
COSTS; [PROPOSED] ORDER
Defendant NBCUniversal Media, LLC ("NBCUniversal") and Plaintiff Anurag Tiwari ("Plaintiff"), through their counsel of record, HEREBY STIPULATE to the following:
WHEREAS, on October 25, 2011, this Court issued an order denying NBCUniversal's motion to dismiss Plaintiff's 42 U.S.C. Section 1983 claim, denying NBCUniversal's motion to strike Plaintiff's intentional infliction of emotional distress claim, granting NBCUniversal's motion to dismiss Plaintiff's defamation claim, and denying NBCUniversal's motion for a protective order staying discovery (Dkt. No. 110);
WHEREAS, this Court has not entered Judgment striking the defamation cause of action;
WHEREAS, NBCUniversal intends to file a motion to recover attorneys' fees and costs regarding the defamation claim pursuant to Code of Civil Procedure § 425.16(c);
WHEREAS, NBCUniversal has requested an extension of time to file its proposed fee motion and Plaintiff has, without conceding the propriety or merits of NBCUniversal's motion, agreed to NBCUniversal's extension request;
NOW, THEREFORE, the parties do hereby stipulate and agree, and they request that this Court Order, that NBCUniversal's time for filing a motion to recover attorneys' fees and costs pursuant to Code of Civil Procedure § 425.16(c) be extended until 30 days after the Court enters Judgment.
Respectfully submitted this 4th day of November, 2011.
DAVIS WRIGHT TREMAINE LLP
Thomas R. Burke
Attorneys for Defendant NBCUniversal Media,
LLC
Elizabeth Pritzker
Attorneys for Plaintiff Anurag Tiwari
Pursuant to Stipulation, It Is So Ordered:
Judge Edward M. Chen