Piracha v. Colvin

Filing 16

STIPULATION AND ORDER re 15 STIPULATION WITH PROPOSED ORDER to Extend Defendant's Time to File Her Motion for Summary Judgment (First Request) filed by Nancy A. Berryhill. Signed by Judge Jon S. Tigar on September 5, 2017. (wsn, COURT STAFF) (Filed on 9/5/2017)

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BRIAN STRETCH, SBN CA 163793
United States Attorney
SARA WINSLOW, DCBN 457643
Chief of the Civil Division
DEBORAH STACHEL, SBN CA 230138
Regional Chief Counsel, Region IX
Social Security Administration
JENNIFER KENNEY, SBN CA 241625
Special Assistant United States Attorney
160 Spear Street, Suite 800
San Francisco, California 94105
Telephone: [phone]
Facsimile: [phone]
E-Mail: [e-mail]
Attorneys for Defendant

NORTHERN DISTRICT OF CALIFORNIA
Attorneys for Defendant
JENNIFER PIRACHA,
Attorneys for Defendant
Plaintiff,
vs.

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NANCY A. BERRYHILL,
Acting Commissioner of
Social Security,

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Defendant.

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UNITED STATES DISTRICT COURT

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CIVIL NO. 3:17-CV-00129-JST
STIPULATION TO EXTEND
DEFENDANT’S TIME TO FILE HER
MOTION FOR SUMMARY
JUDGMENT (FIRST REQUEST)
AND [PROPOSED] ORDER

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TO THE HONORABLE JON S. TIGAR, DISTRICT JUDGE OF THE DISTRICT COURT:

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The parties, through their undersigned attorneys, and with the approval of the Court, stipulate to
extend Defendant’s time to file her motion for summary judgment by two weeks (14 days), from

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September 5, 2017 to September 19, 2017. Defendant respectfully requests this first extension of time

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due to a significant, unexpected increase in workload, including taking over an employment law matter

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in the middle of litigation from a colleague experiencing a personal emergency. This is in addition to

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Defendant’s counsel’s already extremely busy workload, including more than a dozen pending Ninth

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Stip. & Proposed Order for Extension, 3:17-CV-00129-JST
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Circuit and district court cases, and other employment law matters in litigation before the Equal

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Employment Opportunity Commission and the Merit System Protection Board.

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The parties further stipulate that Plaintiff shall have an additional two weeks (14 days) to file a

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Reply because Plaintiff's attorney will be out of the office on a planned vacation from September 23
through October 9. The new due date of Plaintiff's Reply is October 17, 2017.

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Respectfully submitted,

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Date: September 1, 2017

By:

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Date: September 1, 2017

BRIAN STRETCH
United States Attorney

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By:

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/s/ * Donald Medearis
DONALD MEDEARIS
(*authorized by email on Sept. 1, 2017)
Attorneys for Plaintiff

/s/ Jennifer A. Kenney
JENNIFER A. KENNEY
Special Assistant United States Attorney

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ORDER
PURSUANT TO STIPULATION, IT IS SO ORDERED:

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Dated: September 5, 2017
HON. JON S. TIGAR
UNITED STATES DISTRICT JUDGE

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Stip. & Proposed Order for Extension, 3:17-CV-00129-JST
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