Torrez v. Berryhill
Filing
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STIPULATION AND ORDER re 13 STIPULATION WITH PROPOSED ORDER For An Extension of Time of 60 Days for Defendant's Response to Plaintiff's Motion for Summary Judgment filed by Nancy A. Berryhill. Signed by Judge Jon S. Tigar on August 29, 2017. (wsn, COURT STAFF) (Filed on 8/29/2017)
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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: (415) 977-8956
Facsimile: (415) 744-0134
E-Mail: Carolyn.Chen@ssa.gov
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Attorneys for Defendant
UNITED STATES DISTRICT COURT
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NORTHERN DISTRICT OF CALIFORNIA
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SALLY TORREZ,
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-01586-JST
STIPULATION FOR AN EXTENSION OF
TIME OF 60 DAYS FOR DEFENDANT’S
RESPONSE TO PLAINTIFF’S MOTION
FOR SUMMARY JUDGMENT
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 60 days to
respond to Plaintiff’s motion for summary judgment. This is the first continuance sought by
Defendant. The current due date is August 31, 2017. The new due date will be October 30,
2017.
There is good cause for this request. Since the filing of Plaintiff’s Motion for Summary
Judgment on August 3, 2017, Defendant’s counsel has been diligently addressing her full
workload and was assigned additional and unanticipated matters that had immediate deadlines
and could not be assigned to another attorney, including filing objections or motions in response
two district court decisions decided on July 31, 2017, and August 4, 2017, with deadlines that
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could not be extended. Despite counsel’s diligence in responding to the new matters and her
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remaining workload, counsel was set back in addressing her other cases, including this one.
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Moreover, in the next 60 days, Defendant’s counsel will be addressing other cases that have
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previously been extended, new assignments that have deadlines that cannot be extended, as well
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as an Equal Employment Opportunity Commission matter involving discovery and travel for
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depositions and subsequent briefing, that has also been extended once. Therefore, Defendant is
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respectfully requesting additional time up to and including October 30, 2017, to fully review the
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record and research the issues presented by Plaintiff’s motion for summary judgment in this case.
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This request is made in good faith with no intention to unduly delay the proceedings. Defendant
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apologizes for the delay and any inconvenience caused by the delay.
The parties further stipulate that the Court’s Scheduling Order shall be modified
accordingly.
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Respectfully submitted,
Date: August 29, 2017
HOMELESS ACTION CENTER
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s/ Paul Kim by C.Chen*
(As authorized by e-mail on 8/29/2017)
PAUL KIM
Attorney for Plaintiff
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Date: August 29, 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
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APPROVED AND SO ORDERED:
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DATED: August 29, 2017
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