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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1 2 3 4 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 5 160 Spear Street, Suite 800 San Francisco, California 94105 Telephone: (415) 977-8956 Facsimile: (415) 744-0134 E-Mail: 6 7 8 9 Attorneys for Defendant UNITED STATES DISTRICT COURT 10 NORTHERN DISTRICT OF CALIFORNIA 11 12 13 REGGIE CRANE, Plaintiff, 14 16 vs. NANCY A. BERRYHILL, Acting Commissioner of Social Security, 17 Defendant. 15 18 ) ) ) ) ) ) ) ) ) ) ) ) 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 19 IT IS HEREBY STIPULATED, by and between the parties, through their respective 20 21 22 23 24 25 26 27 28 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 1 1 assigned additional unanticipated matters that involved hearing and witness preparation. Despite 2 counsel’s diligence in responding to the new matters and her remaining workload, counsel was 3 set back in addressing a number of her cases, including this one and other cases that have been 4 extended. Furthermore, Defendant’s counsel will be traveling for work, attending two hearings, 5 and conducting additional depositions in the remainder of October and November. 6 Therefore, Defendant is respectfully requesting additional time up to and including 7 November 27, 2017, to fully review the record and research the issues presented by Plaintiff’s 8 motion for summary judgment in this case. This request is made in good faith with no intention 9 to unduly delay the proceedings. 10 11 The parties further stipulate that the Court’s Scheduling Order shall be modified accordingly. 12 13 Respectfully submitted, Date: October 12, 2017 TONY ARJO, ATTORNEY AT LAW 14 s/ Tony Arjo by C.Chen* (As authorized by phone on 10/12/2017) TONY ARJO Attorney for Plaintiff 15 16 17 18 Date: October 12, 2017 19 BRIAN J. STRETCH United States Attorney By s/ Carolyn B. Chen CAROLYN B. CHEN Special Assistant U. S. Attorney 20 21 Attorneys for Defendant 22 23 24 25 ORDER APPROVED AND SO ORDERED: 26 27 28 DATED: October 13, 2017 _________________________________ HON. WILLIAM H. ORRICK UNITED STATES DISTRICT JUDGE 2

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