Raven-Jones v. Colvin

Filing 24

STIPULATION AND ORDER for Plaintiff's first extension to file reply to Defendant's cross motion for summary judgment. Replies due by 3/20/2017. Signed by Judge Laurel Beeler on 2/23/2017. (tmiS, COURT STAFF) (Filed on 2/24/2017)

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HEATHER M. FREINKEL, SBN 272931
HOMELESS ACTION CENTER
2601 San Pablo Ave.
Oakland, CA 94612
Phone: [phone] x. 322
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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JAMI RAVEN-JONES,

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CIVIL NO. CIVIL NO. 3:16-cv-03766-LB

Plaintiff,

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v.

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NANCY A. BERRYHILL,

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STIPULATION AND PROPOSED ORDER
FOR A FIRST EXTENSION FOR
PLAINTIFF TO FILE REPLY TO
DEFENDANT’S CROSS MOTION FOR
SUMMARY JUDGMENT

Acting Commissioner of Social Security, 1

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Defendant.

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IT IS HEREBY STIPULATED, by and between the parties, through their respective
counsel of record, that Plaintiff shall have a first extension of time of twenty-one days to file her

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Nancy A. Berryhill is now the Acting Commissioner of Social Security. Pursuant to Rule 25(d)
of the Federal Rules of Civil Procedure, Nancy A. Berryhill should be substituted for Acting
Commissioner Carolyn W. Colvin as the defendant in this suit. No further action needs to be
taken to continue this suit by reason of the last sentence of section 205(g) of the Social Security
Action, 42 U.S.C. §405(g).”
STIPULATION AND PROPOSED ORDER FOR FIRST EXTENSION FOR PLAINTIFF’S REPLY
16-CV-03766-LB

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reply to Defendant’s motion for summary judgment. The current due date is February 27, 2017.

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The new due date will be March 20, 2017.

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This is the first continuance sought by Plaintiff. There is good cause for this request.

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Plaintiff seeks this extension due to counsel’s heavy workload, including her administrative

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hearing caseload with the Social Security Administration.

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Plaintiff apologizes for any inconvenience caused by this delay. Defendant does not
object and agrees that all subsequent filing deadlines should be extended accordingly.

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Dated this 21st Day of February, 2017

Respectfully Submitted,

Dated: February 21, 2017

_/s/ Heather M. Freinkel_________

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HEATHER M. FREINKEL
Attorney for JAMI RAVEN-JONES
HOMELESS ACTION CENTER
2601 San Pablo Ave.
Oakland, CA 94612

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Dated: February 21, 2017

_/s/ Beatrice Na *___________

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BEATRICE NA
Attorney for NANCY A. BERRYHILL
(*Authorized via email on 2/21/17)
160 Spear Street, Suite 800
San Francisco, CA 94105

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PURSUANT TO THE ABOVE STIPULATION, IT IS SO ORDERED:

2/23/2017
Dated:_____________

____________________________
THE HONORABLE LAUREL BEELER
United States Magistrate Judge

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STIPULATION AND PROPOSED ORDER FOR FIRST EXTENSION FOR PLAINTIFF’S REPLY
16-CV-03766-LB

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