Taverniti v. Astrue

Filing 23

STIPULATION AND ORDER re 22 Stipulation for a Third Extension for Defendant to Answer or Otherwise Respond to Plaintiff's Complaint. Signed by Chief Judge James Ware on July 10, 2012. (wsn, COURT STAFF) (Filed on 7/10/2012)

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UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF CALIFORNIA
SAN FRANCISCO DIVISION

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Attorneys for Defendant

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160 Spear Street, 8th Floor
San Francisco, California 94105
Telephone: [phone]
Facsimile: [phone]
Email: [e-mail]

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DERED

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MELINDA L. HAAG CSBN 132612
United States Attorney
DONNA L. CALVERT, SBN IL 6191786
Acting Regional Chief Counsel, Region IX
ELIZABETH BARRY, CSBN 203314
Special Assistant United States Attorney

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DALENA M. TAVERNITI,

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Plaintiff,
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v.
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MICHAEL J. ASTRUE,
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Commissioner of Social Security,
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Defendant.
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CASE NO.: C-3:11-cv-06659-JW
STIPULATION AND PROPOSED ORDER
FOR A THIRD EXTENSION FOR
DEFENDANT TO ANSWER OR OTHERWISE
RESPOND TO PLAINTIFF’S COMPLAINT

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IT IS HEREBY STIPULATED by the undersigned for the respective parties, subject to the

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approval of the Court, that the Commissioner shall have a 30-day extension of time in which to answer

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or otherwise respond to Plaintiff’s Complaint. The extension is requested because meaningful review of

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this case is not possible, as the Commissioner has not yet received the administrative record and other

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pertinent information from the Appeals Council. The undersigned Defendant’s counsel has been

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informed that this plaintiff has a lengthy administrative history with the Social Security Administration,

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which dates back to the mid-1980s, and apparently the administrative record in this matter is very

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involved. The undersigned defense counsel is in communication with the Appeals Council and hopes to

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obtain the necessary information shortly. This stipulation is not intended to cause unreasonable delay.

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This is the Commissioner’s third request for an extension. The Commissioner’s answer to
Plaintiff’s Complaint is due July 6, 2012; it will now be due August 6, 2012.

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Respectfully submitted,
Dated: July 6, 2012

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/s/ Robert Weems
ROBERT WEEMS
Attorney for Plaintiff

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MELINDA L. HAAG
United States Attorney

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Dated: July 6, 2012

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By /s/ Elizabeth Barry
ELIZABETH BARRY
Special Assistant U.S. Attorney
Attorneys for Defendant

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ORDER

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PURSUANT TO STIPULATION, IT IS SO ORDERED.
July 10, 2012
DATED:________________________

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JAMES WARE
UNITED STATES DISTRICT JUDGE

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