Reggie Crane v. Nancy Berryhill

Filing 21

STIPULATION AND ORDER re 20 STIPULATION WITH PROPOSED ORDER For An Extension of Time of 45 Days for Defendant's Response to Plaintiff's Motion for Summary Judgment filed by Nancy A. Berryhill. Signed by Judge William H. Orrick on October 13, 2017. (wsn, COURT STAFF) (Filed on 10/13/2017)

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BRIAN J. STRETCH, CSBN 163973
United States Attorney
DEBORAH LEE STACHEL, CSBN 230138
Regional Chief Counsel, Region IX
Social Security Administration
CAROLYN B. CHEN, CSBN 256628
Special Assistant United States Attorney

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160 Spear Street, Suite 800
San Francisco, California 94105
Telephone: [phone]
Facsimile: [phone]
E-Mail: [e-mail]

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Attorneys for Defendant
UNITED STATES DISTRICT COURT

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NORTHERN DISTRICT OF CALIFORNIA

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REGGIE CRANE,
Plaintiff,

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vs.
NANCY A. BERRYHILL,
Acting Commissioner of Social Security,

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Defendant.

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Case No.: 3:17-cv-01433-WHO
STIPULATION FOR AN EXTENSION OF
TIME OF 45 DAYS FOR DEFENDANT’S
RESPONSE TO PLAINTIFF’S MOTION
FOR SUMMARY JUDGMENT

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IT IS HEREBY STIPULATED, by and between the parties, through their respective

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counsel of record, that Defendant shall have an extension of time of an additional 45 days to
respond to Plaintiff’s motion for summary judgment. This is the first continuance sought by
Defendant. The current due date is October 13, 2017. The new due date will be November 27,
2017.
There is good cause for this request. Since the filing of Plaintiff’s motion for summary
judgment, Defendant’s counsel has been diligently addressing her full workload including
several district court cases and one Equal Employment Opportunity Commission matter
involving discovery, depositions, and travel. In addition, in October, Defendant’s counsel was

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assigned additional unanticipated matters that involved hearing and witness preparation. Despite

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counsel’s diligence in responding to the new matters and her remaining workload, counsel was

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set back in addressing a number of her cases, including this one and other cases that have been

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extended. Furthermore, Defendant’s counsel will be traveling for work, attending two hearings,

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and conducting additional depositions in the remainder of October and November.

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Therefore, Defendant is respectfully requesting additional time up to and including

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November 27, 2017, to fully review the record and research the issues presented by Plaintiff’s

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motion for summary judgment in this case. This request is made in good faith with no intention

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to unduly delay the proceedings.

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The parties further stipulate that the Court’s Scheduling Order shall be modified
accordingly.

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Respectfully submitted,
Date: October 12, 2017

TONY ARJO, ATTORNEY AT LAW

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s/ Tony Arjo by C.Chen*
(As authorized by phone on 10/12/2017)
TONY ARJO
Attorney for Plaintiff

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Date: October 12, 2017

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BRIAN J. STRETCH
United States Attorney
By s/ Carolyn B. Chen
CAROLYN B. CHEN
Special Assistant U. S. Attorney

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Attorneys for Defendant

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ORDER
APPROVED AND SO ORDERED:

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DATED: October 13, 2017

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HON. WILLIAM H. ORRICK
UNITED STATES DISTRICT JUDGE

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