Nunez v. PG&E Retirement Plan, Case No. 16-cv-07412-JST

Stipulation to Enlargement of Time to File Fee Petition, and [proposed] ORDER 1

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CREITZ & SEREBIN LLP

Joseph A. Creitz (SBN 169552)

joe@creitzserebin.com

Lisa S. Serebin (SBN 146312)

lisa@creitzserebin.com

100 Pine St., Ste. 1250

San Francisco, CA 94111

415.466.3090 (tel)

415.513.4475 (fax)

Attorneys for Interpleader Defendant 

ADRIANA VANESSA NUÑEZ

UNITED STATES DISTRICT COURT

FOR THE NORTHERN DISTRICT OF CALIFORNIA

SAN FRANCISCO DIVISION

GLORIA NUNEZ,

Plaintiff,

v.

PACIFIC GAS AND ELECTRIC

COMPANY RETIREMENT PLAN,

Defendant.

Case No. 3:16-cv-07412-JST

STIPULATED REQUEST FOR A 

21-DAY ENLARGEMENT OF TIME 

FOR ADRIANNA VANESSA NUÑEZ 

TO FILE A FEE PETITION

(Dkt. 67, L.R. Civ. 6-3)

and

[proposed] ORDER

PACIFIC GAS AND ELECTRIC 

COMPANY RETIREMENT PLAN,

Counterclaim/Interpleader-Plaintiff,

v.

GLORIA NUNEZ, and ADRIANA 

VANESSA NUÑEZ,

Interpleader Defendants.
Nunez v. PG&E Retirement Plan, Case No. 16-cv-07412-JST

Stipulation to Enlargement of Time to File Fee Petition, and [proposed] ORDER 2

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Pursuant to Civil Local Rule 6-3, the undersigned counsel for Interpleader 

Defendant Adrianna Vanessa Nuñez, and Plaintiff and Interpleader Defendant Gloria 

Nuñez, hereby stipulate and agree as follows:

(1) Pursuant to the Court’s Order of February 12, 2018 (Dkt. 67), Interpleader 

Defendant Adrianna Vanessa Nuñez must file a fee petition, if any, no later than March 

5, 2018. 

(2) The undersigned counsel for Interpleader Defendant Adrianna Vanessa Nuñez 

is serving as first-chair in a jury trial that commences Friday February 23, 2018, and runs 

through March 9, 2018, at the earliest. The case is Kanellakopoulos v. Unimerica Life Insurance 

Co., No. 15-cv-4674-BLF, proceeding before the Honorable District Judge Beth Freeman 

in San Jose.

(3) Because of the time demands of the trial and trial preparation, it will not be 

feasible for counsel to Adriana Vanessa Nuñez to generate a fee petition by the March 5, 

2018 date currently prescribed by the Court’s Order (Dkt. 67).

(5) There are no prior requests by the parties to enlarge time.

(6) Granting the instant Stipulation to enlarge the due date for a fee petition will 

not affect any other date currently prescribed by the Court.

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Nunez v. PG&E Retirement Plan, Case No. 16-cv-07412-JST

Stipulation to Enlargement of Time to File Fee Petition, and [proposed] ORDER 3

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WHEREFORE, the undersigned hereby stipulate and agree that the deadline for 

Interpleader Defendant Adrianna Vanessa Nuñez to file a fee petition, currently 

prescribed by the Court’s Order of February 12, 2018 (Dkt. 67) shall be enlarged by 

twenty-one days, to and including March 26, 2018.

Dated: February 20, 2018 CREITZ & SEREBIN LLP

By: /s/ Joseph A. Creitz

Attorneys for Interpleader Defendant 

ADRIANA VANESSA NUÑEZ

Dated: February 20, 2018 IBARRA PROFESSIONAL LAW 

CORPORATION

By: /s/ Gener Benitez

Gener Benitez

Attorneys for Plaintiff and Interpleader 

Defendant GLORIA NUÑEZ

SIGNATURE ATTESTATION

I hereby attest that I obtained the consent of all signatories hereto to the filing of 

this document.

Dated: February 20, 2018 CREITZ & SEREBIN LLP

By: /s/ Joseph A. Creitz

Attorneys for Interpleader Defendant 

ADRIANA VANESSA NUÑEZ
Nunez v. PG&E Retirement Plan, Case No. 16-cv-07412-JST

Stipulation to Enlargement of Time to File Fee Petition, and [proposed] ORDER 4

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[proposed] ORDER

Pursuant to the stipulation of the parties, and good cause appearing, the deadline 

for Interpleader Defendant Adrianna Vanessa Nuñez to file a fee petition, if any, shall be 

enlarged by twenty-one days, to and including March 26, 2018.

IT IS SO ORDERED

Dated: , 2018

UNITED STATES DISTRICT JUDGE

February 21