Bell v. Colvin

Filing 18

STIPULATION AND ORDER FOR EXTENSION OF TIME. Signed by Judge Maxine M. Chesney on July 26, 2016. (mmclc2, COURT STAFF) (Filed on 7/26/2016)

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BRIAN J. STRETCH (CABN 163973)
United States Attorney
SARA WINSLOW (DCBN 457643)
Chief, Civil Division
HEATHER M. MOSS (DCBN 995773)
Special Assistant U.S. Attorney
160 Spear Street, Suite 800
San Francisco, CA 94105
Telephone: [phone]
Fax: [phone]

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Attorneys for Defendant
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UNITED STATES DISTRICT COURT
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NORTHERN DISTRICT OF CALIFORNIA
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JENNIFER LYNN BELL,
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Plaintiff,
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vs.
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CAROLYN W. COLVIN,
Acting Commissioner of Social Security,
Defendant.

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) CIVIL NO. 3:16-cv-00809-MMC
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) STIPULATION AND PROPOSED
) ORDER FOR EXTENSION OF TIME
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IT IS HEREBY STIPULATED, by and between the parties, through their respective counsel of

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record, that Defendant shall have an extension of time of 30 days, until August 28, 2016, to file a

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response to Plaintiff’s Motion for Summary Judgement. This first extension is needed due to the size of

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the administrative record, and to adequately address the numerous issues and contentions raised.

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Additionally, the undersigned will be on previously approved leave (which includes international
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travel) and has a voluminous caseload (which includes active Bankruptcy cases and employment

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matters before the Equal Employment Opportunity Commission). Counsel for Defendant sincerely

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apologizes for any inconvenience this may cause.

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//

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Stip. & Prop. Order for Ext., 3:16-cv-00809-MMC 1

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Respectfully submitted,
Dated: July 26, 2016

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By: /s/ William D. Namnath*
WILLIAM D. NAMNATH
Attorney for Plaintiff
(*as authorized by email on July 26, 2016)

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Dated: July 26, 2016

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BRIAN J. STRETCH
United States Attorney
SARA WINSLOW
Chief, Civil Division
By: /s/ Heather M. Moss
HEATHER M. MOSS
Special Assistant United States Attorney
Attorneys for Defendant

Of Counsel:
DEBORAH LEE STACHEL,
Acting Regional Chief Counsel

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ORDER

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PURSUANT TO STIPULATION, IT IS SO ORDERED.
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July 26, 2016
DATED:________________________

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THE HONORABLE HON. MAXINE M. CHESNEY
UNITED STATES DISTRICT COURT JUDGE

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Stip. & Prop. Order for Ext., 3:16-cv-00809-MMC 2