Billups v. Berryhill

Filing 21

STIPULATION AND ORDER FOR AN EXTENSION OF TIME Signed by Judge Elizabeth D. Laporte on December 12, 2018. (mllS, COURT STAFF) (Filed on 12/12/2018)

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ALEX G. TSE, CSBN 152348
Acting United States Attorney
DEBORAH LEE STACHEL, CSBN 230138
Regional Chief Counsel, Region IX
Social Security Administration
ALLISON J. CHEUNG, CSBN 244651
Special Assistant United States Attorney
160 Spear Street, Suite 800
San Francisco, CA 94105-1545
Telephone: [phone]
Facsimile: [phone]
E-mail: [e-mail]
Attorneys for Defendant

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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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WALTER BILLUPS,
Plaintiff,

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vs.

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NANCY A. BERRYHILL,
Acting Commissioner of Social Security,

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Defendant.

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) Case No. 3:18-cv-03098-EDL
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) STIPULATION AND [PROPOSED]
) ORDER FOR AN EXTENSION OF TIME
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IT IS HEREBY STIPULATED, by and between the parties through their respective
counsel of record, with the Court’s approval, that Defendant shall have a 21-day extension of
time, from December 13, 2018 to January 3, 2019, for Defendant to respond to Plaintiff’s Motion
for Summary Judgment (Dkt. No. 18).

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Stip. to Extend Time & Prop. Order; 3:18-cv-3098

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This is Defendant’s first request for an extension of time. Defendant submits that good
cause exists for this extension because the parties have recently engaged in settlement
discussions and could not agree on the issue of remedy. Defendant anticipates filing a Motion
for Remand, which will significantly reduce the number of issues that this Court will need to
resolve and will largely focus on whether this matter should be remanded for further proceedings
or an award of benefits. The requested extension will also help accommodate Defendant’s
counsel’s workload, which includes a Ninth Circuit answering brief, numerous other district

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court cases, and other substantive non-litigation matters within the Office of General Counsel.

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Defendant’s counsel will endeavor to complete the response as soon as possible. This request is

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made in good faith and with no intention to unduly delay the proceedings, and counsel

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apologizes for any inconvenience.

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Plaintiff does not oppose Defendant’s request for an extension of time. The parties
further stipulate that the deadline for any reply by Plaintiff will be extended accordingly.

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Respectfully submitted,
Dated: December 12, 2018

Anne M. Su
(*as authorized via email on December 11, 2018)
ANNE M. SU
Attorney for Plaintiff

Dated: December 12, 2018

ALEX G. TSE
Acting United States Attorney
DEBORAH LEE STACHEL
Regional Chief Counsel, Region IX
Social Security Administration

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By:

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/s/ Allison J. Cheung
ALLISON J. CHEUNG
Special Assistant U.S. Attorney
Attorneys for Defendant

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Stip. to Extend Time & Prop. Order; 3:18-cv-3098

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ORDER

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Pursuant to stipulation, IT IS SO ORDERED.

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Dated: _12/12/18_____

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__________________________________
THE HONORABLE ELIZABETH D. LAPORTE
United States Magistrate Judge

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Stip. to Extend Time & Prop. Order; 3:18-cv-3098

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