Piracha v. Colvin

Filing 13

STIPULATION AND ORDER re 12 STIPULATION WITH PROPOSED ORDER filed by Jennifer Piracha. Signed by Judge Jon S. Tigar on May 16, 2017. (wsn, COURT STAFF) (Filed on 5/16/2017)

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DONALD H. MEDEARIS, SBN 206849
BAY AREA LEGAL AID
1800 Market Street, 3rd Floor
San Francisco, CA 94102
Telephone: [phone]
Fax: [phone]
[e-mail]
Attorney for Plaintiff,
JENNIFER PIRACHA

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UNITED STATES DISTRICT COURT

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NORTHERN DISTRICT OF CALIFORNIA

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SAN FRANCISCO DIVISION

11 JENNIFER PIRACHA,
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)
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Plaintiff,
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vs.
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NANCY A.BERRYHILL, Commissioner of the )
Social Security Administration,
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Defendant.
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Case No. 3:17-CV-00129-JST
STIPULATION AND PROPOSED ORDER
FOR AN EXTENSION OF TIME FOR
PLAINTIFF TO FILE MOTION FOR
SUMMARY JUDGMENT

IT IS HEREBY STIPULATED, by and between parties, through their representative
counsel of record, that Plaintiff shall have a first extension of time of 70 days to file her

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Motion For Summary Judgement in response to Defendant's Answer . The new date for filing
Plaintiff's Motion for Summary Judgement will be August 7, 2017.
This extension is necessary because Donald H. Medearis substituted in as Plaintiff's
attorney on May 10, 2017, and although he represented the Plaintiff in her Social Security
Appeals Council case, he did not represent her at her Administrative Law Judge hearing,

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needs more time to familiarize himself with the law and facts of the case and has a heavy

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STIPULATION TO EXTENSION OF TIME FOR PLAINTIFF TO FILE MOTION FOR
SUMMARY JUDGMENT, AND PROPOSED ORDER; CASE NO. 3:17-CV-00129-JST

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caseload and work schedule. Plaintiff's Attorney apologizes to the Court and Opposing

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Counsel for the delay. The parties further stipulate that the Court's Scheduling Order shall be

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modified accordingly.

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Respectfully submitted,

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Dated: May 10, 2017

/s/Donald H. Medearis
DONALD H. MEDEARIS
BAY AREA LEGAL AID

Dated: May 10, 2017

BRIAN STRETCH
United States Attorney
SARA WINSLOW
Chief of Civil Division
DEBORAH STACHEL
Regional Chief Counsel, Region IX
Social Security Administration

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By:

/s/Jennifer A. Kenney
(* as authorized by e-mail on May 10, 2017)
JENNIFER A. KENNEY
Special Assistant United States Attorney
Attorneys for Defendant

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S

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J u d ge J o

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RDERE

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By:_____________________________
IT IS S
THE HONORABLE JON S. TIGAR

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R NIA

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May 16, 2017
Dated: ____________

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APPROVED AND SO ORDERED

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ORDER:

UNIT
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STIPULATION TO EXTENSION OF TIME FOR PLAINTIFF TO FILE MOTION FOR
SUMMARY JUDGMENT, AND PROPOSED ORDER; CASE NO. 3:17-CV-00129-JST

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