Walker v. Colvin

Filing 18

ORDER granting 17 MOTION for Extension of Time. Deadlines reset as to 15 MOTION for Summary Judgment. Response/Counter-Motion for Summary Judgment due by 5/9/2016. Reply/Response due by 5/23/2016. Signed by Judge William H. Orrick on 04/25/2016. (jmdS, COURT STAFF) (Filed on 4/25/2016)

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BRIAN STRETCH, CSBN 163973
United States Attorney
DEBORAH LEE STACHEL, CSBN 230138
Acting Regional Chief Counsel, Region IX
Social Security Administration
PATRICK WILLIAM SNYDER, CSBN 260690
Special Assistant United States Attorney
160 Spear Street, Suite 800
San Francisco, CA 94105
Phone: [phone]
Fax: [phone]
[e-mail]

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Attorneys for Defendant

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UNITED STATES DISTRICT COURT
Attorneys for Defendant
NORTHERN DISTRICT OF CALIFORNIA

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Attorneys for Defendant

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CAROLYN WALKER,

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Plaintiff

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v.

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CAROLYN W. COLVIN, Acting Commissioner
of Social Security,
Defendant.

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Civil No. 3:15-cv-05369 WHO
EX PARTE MOTION TO EXTEND
TIME FOR DEFENDANT TO FILE
HER COUNTER-MOTION FOR
SUMMARY JUDGMENT

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Defendant Carolyn W. Colvin, Acting Commissioner of Social Security, requests to extend the
time by two weeks, from April 25, 2016 to May 9, 2016 for the Commissioner to provide her CounterMotion For Summary Judgment, with all other dates in this Court’s Procedural Order For Social

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Security Review Actions extended accordingly. This is the Commissioner’s first request for an

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extension. The request is being made ex parte because counsel for the Defendant was unable to reach

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Plaintiff’s counsel via telephone or email in the hope of filing a stipulated motion.

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Stipulated Request To Extend Time For Defendant To File MSJ, 3:15-cv-05639 WHO

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Counsel makes this request in good faith. There is good cause for this request because the case
was recently reassigned to new counsel for Defendant, who needs additional time to become familiar
with the facts and the issues presented in the opening brief, as well as a quality review of the brief in

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accordance with our office procedures. There is also good cause for this extension because the

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undersigned counsel is currently responsible for dozens of district court cases at various stages of

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litigation, a Ninth Circuit Privacy Act case which is going to hearing on May 4, 2016, dozens of

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subpoena and disclosure matters, two representative sanction matters, as well as a Federal Tort Claim

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Act and other miscellaneous litigation cases in district court with current filing deadlines. As a result,

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the Commissioner needs additional time to properly address the issues raised in Plaintiff’s Motion For
Summary Judgment.
Respectfully submitted,

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Date: April 22, 2016

BRIAN STRETCH
United States Attorney

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By:

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Of Counsel, JAMES BIELENBERG

/s/ Patrick William Snyder
PATRICK WILLIAM SNYDER
Special Assistant United States Attorney
Attorneys for Defendant

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ORDER

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IT IS ORDERED that the Commissioner shall have until May 9, 2016 to file her Counter-

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Motion For Summary Judgment, with all other dates in this Court’s Procedural Order For Social

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Security Review Actions extended accordingly.

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Date: April 25, 2016

______________________________________________
THE HONORABLE WILLIAM H. ORRICK
United States District Judge

Stipulated Request To Extend Time For Defendant To File MSJ, 3:15-cv-05639 WHO

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