Fleischman v. Berryhill
Filing
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STIPULATION AND ORDER RE 16 FOR A THIRD EXTENSION OF TIME FOR PLAINTIFF TO FILE MOTION FOR SUMMARY JUDGMENT. Signed by Judge Richard Seeborg on 11/20/17. (cl, COURT STAFF) (Filed on 11/20/2017)
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DONALD H.MEDEARIS, SBN 206849
BAY AREA LEGAL AID
1800 MARKET Street, 3rd Floor
San Francisco, CA 94102
Telephone: (415) 354-6331
Fax: (415) 982-4243
dmedearis@baylegal.org
Attorney for Plaintiff,
ADELAIDE FLEISCHMAN
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UNITED STATES DISTRICT COURT
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NORTHERN DISTRICT OF CALIFORNIA
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SAN FRANCISCO DIVISION
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ADELAIDE FLEISCHMAN,
Plaintiff,
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vs.
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NANCY A. BERRYHILL, Acting
Commissioner of the Social Security
Administration,
Defendant.
Case No. 3:17-CV- 01502-RS
STIPULATION AND PROPOSED ORDER
FOR A THIRD EXTENSION OF TIME
FOR PLAINTIFF TO FILE MOTION FOR
SUMMARY JUDGMENT
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IT IS HEREBY STIPULATED, by and between the parties, through their respective
counsel of record, that Plaintiff shall have an extension of time of 7 days to file her Motion
for Summary Judgment in response to Defendant’s Answer. The current date for filing the
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Plaintiff's Motion for Summary Judgment (MSJ) is November 15, 2017. The new due date
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will be November 22, 2017. Plaintiff's attorney came down with a gastrointestinal illness on
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Friday, November 10. Symptoms have continued through today. If the Court needs evidence
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of his November 12 doctor office visit, Plaintiff's attorney is happy to provide it. Plaintiff's
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STIPULATION TO THIRD EXTENSION OF TIME FOR PLAINTIFF TO FILE MOTION
FOR SUMMARY JUDGMENT, AND PROPOSED ORDER; CASE NO. 3:17-CV-01502RS
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attorney has come into the office every day and made his best effort to finish the MSJ, but
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has been working less productively than usual and believes he has a duty to his client to take
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extra time to finish the MSJ. Plaintiff's attorney also wishes to point out that Plaintiff's first
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extension of time was before Plaintiff's attorney substituted in as attorney, replacing the
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Plaintiff who had been Pro Se, and the second extension of time was for 14 days only.
Plaintiff's attorney sincerely apologizes to the Court and to the Defendant for any
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inconvenience caused by this delay. The parties further stipulate that the Court’s Scheduling
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Order shall be modified accordingly.
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Respectfully submitted,
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Dated: 11/15/17
/s/ Donald H. Medearis
DONALD H. MEDEARIS
BAY AREA LEGAL AID
Attorney for Plaintiff
Dated: 11/15/17
BRIAN J. STRETCH
United States Attorney
DEBORAH LEE STACHEL,
Regional Chief Counsel, Region IX Civil
Division
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By:
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/s/ Tina L. Naicker
(* as authorized by e-mail on 11/15/17)
TINA L. NAICKER
Special Assistant U.S. Attorney
Attorneys for Defendant
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ORDER:
APPROVED AND SO ORDERED
11/20/17
Dated: ____________
By: _______________________________
THE HONORABLE JUDGE RICHARD
SEEBORG
United States District Judge
STIPULATION TO THIRD EXTENSION OF TIME FOR PLAINTIFF TO FILE MOTION
FOR SUMMARY JUDGMENT, AND PROPOSED ORDER; CASE NO. 3:17-CV-01502RS
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