People With Disabilities Foundation v. Colvin

Filing 22

ORDER by Judge Haywood S. Gilliam, Jr. Granting 21 Stipulation FOR EXTENSION OF TIME TO NOVEMBER 20, 2015 FOR PLAINTIFF TO FILE OPPOSITION RESPONSE TO DEFENDANT'S 20 MOTION TO DISMISS PLAINTIFF'S FIRST AMENDED COMPLAINT (ndrS, COURT STAFF) (Filed on 11/4/2015)

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STEVEN BRUCE, SBN 70300
People With Disabilities Foundation
507 Polk Street, Suite 430
San Francisco, CA 94102
Phone: [phone]
Fax: [phone]
[e-mail]

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Attorney for Plaintiff
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UNITED STATES DISTRICT COURT
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NORTHERN DISTRICT OF CALIFORNIA
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CASE NO.:
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PEOPLE WITH DISABILITIES

3:15-CV-02570 HSG

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FOUNDATION, INC.
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Plaintiff,
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v.
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CAROLYN COLVIN,
Acting Commissioner of Social Security,

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STIPULATION BETWEEN THE PARTIES
AND ORDER FOR EXTENSION OF TIME
TO NOVEMBER 20, 2015 FOR PLAINTIFF
TO FILE OPPOSITION RESPONSE TO
DEFENDANT’S MOTION TO DISMISS
PLAINTIFF’S FIRST AMENDED
COMPLAINT.

Defendant.
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PRELIMINARY STATEMENT
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Plaintiff, People with Disabilities Foundation (“PWDF”) and Defendant Carolyn Colvin,
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Acting Commissioner of Social Security (“SSA”), by and through their respective counsel,
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submit the following Stipulation, and request that the Court so order it pursuant to Rule 6(b) of
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the Federal Rules of Civil Procedure:
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There have been two previous continuances in this action at the request of the SSA

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and PWDF. See Doc. No 16, 19.

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Plaintiff requests a time extension to November 20, 2015 to file a Response to

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Defendant’s Motion to Dismiss Plaintiff’s First Amended Complaint because

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Plaintiff’s counsel will be in a jury trial in an unrelated case during the first week of

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November when the Opposition motion is currently due to be filed.

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2. The parties stipulate and agree that Defendant’s reply to Plaintiff’s Opposition to

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Defendant’s Motion to Dismiss Plaintiff’s First Amended Complaint will be due on

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December 4, 2015.

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3. The parties further request that the hearing on the motion be continued from
December 17, 2015 to January 7, 2016 at 2:00 p.m.
4. The Case Management Conference will be moved from December 15, 2015 to
February 16, 2016, which is after the hearing on this Motion to Dismiss.

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5. WHEREFORE, the parties hereby stipulate and request that the Court grant Plaintiff

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an extension of time to November 20, 2015 to file an Opposition to Defendant’s

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Motion to Dismiss Plaintiff’s First Amended Complaint in this action.

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DATED: November 2, 2015

Respectfully submitted,

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/s/
STEVEN BRUCE
Attorney for Plaintiff
People With Disabilities Foundation, Inc.

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DATED: November 2, 2015

Respectfully submitted,

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BRIAN J. STRETCH
Acting United States Attorney

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/s/

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ANN MARIE REDING,
Assistant United States Attorney
Attorneys for Defendant

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ORDER
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Plaintiff and Defendant’s Stipulation and Proposed Order granting Plaintiff an extension
to file an OPPOSITION to Defendant’s Motion to Dismiss Plaintiff’s First Amended

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Complaint by November 20, 2015, to extend the Reply date until December 4,

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2015, and to have the hearing on said motion on January 7, 2016 is hereby GRANTED.

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The case management conference scheduled for December 15, 2015 has been continued
to February 16, 2016 at 2:00 p.m.

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DATE: November 4, 2015
HAYWOOD S. GILLIAM, JR.
United States District Judge

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