Brokaw v. Colvin

Filing 12

ORDER by Magistrate Judge Sallie Kim granting 11 Motion TO EXTENDTHE TIME FOR DEFENDANT TO FILE HER ANSWER AND THE CERTIFIED ADMINISTRATIVE (sklc2S, COURT STAFF) (Filed on 12/23/2015) Modified on 12/23/2015 (mklS, COURT STAFF).

1
2
3
4
5
6
7

BRIAN J. STRETCH, CSBN 163973
Acting United States Attorney
DEBORAH LEE STACHEL, CSBN 230138
Acting Regional Chief Counsel, Region IX
Social Security Administration
HENRY L. CHI, CSBN 265009
Special Assistant United States Attorney
160 Spear Street, Suite 800
San Francisco, CA 94105
Telephone: [phone]
Facsimile: 415-744-0134
E-Mail: [e-mail]

8
9

Attorneys for Defendant

10

UNITED STATES DISTRICT COURT

11

NORTHERN DISTRICT OF CALIFORNIA (SAN FRANCISCO)

12

ANITA BROKAW,

13
Plaintiff,
14
15

v.

16

CAROLYN W. COLVIN,
Acting Commissioner of Social Security,

17

Defendant.

18
19
20

)
)
)
)
)
)
)
)
)
)
)
)
)

Civil No. 3:15-cv-04313-SK
DEFENDANT’S EX PARTE MOTION
AND PROPOSED ORDER TO EXTEND
THE TIME FOR DEFENDANT TO FILE
HER ANSWER AND THE CERTIFIED
ADMINISTRATIVE RECORD

Defendant Carolyn W. Colvin, Acting Commissioner of Social Security, through her

21

undersigned attorneys, hereby moves to extend the time by 16 days from December 23, 2015, to

22

January 8, 2016, to file her Answer and the Certified Administrative Record (CAR).

23

There is good cause for this extension because Defendant’s counsel attempted to procure

24

an additional copy of the CAR to serve Plaintiff. Defendant anticipated that it would be received

25

today, but has not received it yet. As such, the additional time is needed to obtain and serve

26

Plaintiff with a copy of the CAR and accommodate the holidays.

27
28

1- Defendant’s Ex Parte Motion and Proposed Order to Extend the Time for Defendant to File
Her Answer and the Certified Administrative Record

1
2

Defendant’s counsel has not contacted Plaintiff to determine whether she consents to
this motion because of the holidays and to file this motion expeditiously.

3
4
5

Respectfully submitted,
Dated: December 23, 2015

BENJAMIN B. WAGNER
United States Attorney

6
7
By:

8
9
10

/s/ Henry L. Chi
HENRY L. CHI
Special Assistant U.S. Attorney
Attorneys for Defendant

11
12
13
14
15
16
17
18

ORDER
APPROVED AND SO ORDERED.
DATED: December 23, 2015
SALLIE KIM
UNITED STATES MAGISTRATE JUDGE

19
20
21
22
23
24
25
26
27
28

2- Defendant’s Ex Parte Motion and Proposed Order to Extend the Time for Defendant to File
Her Answer and the Certified Administrative Record

1
2
3
4
5
6

CERTIFICATE OF SERVICE
I, the undersigned, am a citizen of the United States, and am at least eighteen years of age.
My business address is 160 Spear Street, Suite 800, San Francisco, California 94105. On
December 23, 2015, I caused service of Defendant’s Ex Parte Motion and Proposed Order to
Extend the Time for Defendant to File Her Answer and the Certified Administrative Record via
certified mail, return receipt, and regular mail to the following address:

7
8
9
10

Anita Brokaw
1874 Fred Jackson Way
Richmond, CA 94801
I declare under penalty of perjury that the foregoing is true and correct.

11
12

Dated: December 23, 2015

BENJAMIN B. WAGNER
United States Attorney

13
14
15
16

By:

/s/ Henry L. Chi
HENRY L. CHI
Special Assistant U.S. Attorney
Attorneys for Defendant

17
18
19
20
21
22
23
24
25
26
27
28

3- Defendant’s Ex Parte Motion and Proposed Order to Extend the Time for Defendant to File
Her Answer and the Certified Administrative Record