Opinion
Case No. C 11-02267 DMR
03-13-2013
GONZALES & GONZALES BONDS AND INSURANCE AGENCY, INC., Plaintiff, v. UNITED STATES DEPARTMENT OF HOMELAND SECURITY, Defendant.
ROXBOROUGH, POMERANCE, NYE & ADREANI, LLP Gary A. Nye David R. Ginsburg Attorneys for Plaintiff Gonzales & Gonzales Bonds and Insurance Agency, Inc. MELINDA HAAG United States Attorney ANN MARIE REDING Assistant United States Attorney Attorneys for Defendant 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
5820 Canoga Avenue, Suite 250
Woodland Hills, California 91367
Telephone: (818) 992-9999
Facsimile: (818) 992-9991
Email: gan@rpnalaw.com; drg@rpnalaw.com
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
450 Golden Gate Avenue, Box 36055
San Francisco, California 94102-3495
Telephone: (415) 436-6813
Fax: (415) 436-6748
Email: annie.reding@usdoj.gov
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 12, 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.
The current filing deadline for the motion and bill of costs is March 19, 2013. Based on their most recent meet and confer, the parties agree that an extension to April 2, 2013 would allow for further meaningful discussion. The parties therefore respectfully request that the Court approve this requested extension.
This is the fourth 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
______________________
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 March 19, 2013 to April 2, 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