Bell v. Colvin

Filing 23

STIPULATION AND ORDER FOR EXTENSION OF TIME. Plaintiff shall have an extension until November 11, 2016 to file a reply to defendant's opposition and cross-motion for summary judgment. Signed by Judge Maxine M. Chesney on 10/13/16. (mmclc2, COURT STAFF) (Filed on 10/13/2016)

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William D. Namnath, Attorney at Law
CSBN 235347
Napa, CA 94581
P.O. Box 6678
Tele: [phone]
Fax: [phone]
Email: [e-mail]
Attorney for Plaintiff, Jennifer Lynn Bell

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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,

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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 Plaintiff shall have an extension of time of 30 days, until November 11, 2016, to file a reply

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to Defendant’s Cross-Motion for Summary Judgment and Opposition to Plaintiff’s for Summary

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Judgment. This first extension is needed due to the size of the administrative record, and to adequately

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address the numerous issues and contentions raised. Counsel for Plaintiff sincerely apologizes for any
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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: October 12, 2016

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By: /s/ William D. Namnath
WILLIAM D. NAMNATH
Attorney for Plaintiff

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Dated: October 12, 2016

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BRIAN J. STRETCH
United States Attorney
SARA WINSLOW
Chief, Civil Division
By: /s/ Geralyn Gulseth o/b/o Heather Moss*
HEATHER M. MOSS
Special Assistant United States Attorney
Attorneys for Defendant
(*as authorized by email on October 12, 2016)

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Of Counsel:

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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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October 13, 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