Torrez v. Berryhill

Filing 14

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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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: Carolyn.Chen@ssa.gov 6 7 8 9 Attorneys for Defendant UNITED STATES DISTRICT COURT 10 NORTHERN DISTRICT OF CALIFORNIA 11 12 13 SALLY TORREZ, Plaintiff, 14 16 vs. NANCY A. BERRYHILL, Acting Commissioner of Social Security, 17 Defendant. 15 18 21 22 23 24 25 26 27 28 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 19 20 ) ) ) ) ) ) ) ) ) ) ) ) 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 1 1 could not be extended. Despite counsel’s diligence in responding to the new matters and her 2 remaining workload, counsel was set back in addressing her other cases, including this one. 3 Moreover, in the next 60 days, Defendant’s counsel will be addressing other cases that have 4 previously been extended, new assignments that have deadlines that cannot be extended, as well 5 as an Equal Employment Opportunity Commission matter involving discovery and travel for 6 depositions and subsequent briefing, that has also been extended once. Therefore, Defendant is 7 respectfully requesting additional time up to and including October 30, 2017, to fully review the 8 record and research the issues presented by Plaintiff’s motion for summary judgment in this case. 9 This request is made in good faith with no intention to unduly delay the proceedings. Defendant 10 11 12 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. 13 14 Respectfully submitted, Date: August 29, 2017 HOMELESS ACTION CENTER 15 s/ Paul Kim by C.Chen* (As authorized by e-mail on 8/29/2017) PAUL KIM Attorney for Plaintiff 16 17 18 19 Date: August 29, 2017 20 BRIAN J. STRETCH United States Attorney By s/ Carolyn B. Chen CAROLYN B. CHEN Special Assistant U. S. Attorney 21 22 Attorneys for Defendant 23 24 ORDER 25 26 APPROVED AND SO ORDERED: 27 DATED: August 29, 2017 28 2

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