Adela E. Gomez v. Nancy A. Berryhill

Filing 22

STIPULATION AND ORDER re 21 . STIPULATION WITH PROPOSED ORDER Extending Defendant's time to file a responsive pleading filed by Nancy A. Berryhill. Signed by Magistrate Judge Kandis A. Westmore on 12/19/17. (sisS, COURT STAFF) (Filed on 12/19/2017)

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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
RICHARD M. RODRIGUEZ
Special Assistant United States Attorney
160 Spear Street, Suite 800
San Francisco, California 94105
Telephone: [phone]
Facsimile: [phone]
E-Mail: [e-mail]

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UNITED STATES DISTRICT COURT
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NORTHERN DISTRICT OF CALIFORNIA
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ADELA E. GOMEZ
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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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STIPULATION AND PROPOSED
ORDER EXTENDING DEFENDANT’S
TIME TO FILE A RESPONSE TO
PLAINTIFF’S MOTION FOR
SUMMARY JUDGMENT AND
MEMORANDUM OF POINTS AND
AUTHORITIES
(Defendant’s First Extension Request)

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CIVIL NO. 4:17-cv-01473-KAW

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Stipulation re: extension, 4:17-cv-01473-KAW

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Defendant Nancy A. Berryhill, Acting Commissioner of the Social Security Administration
(“Defendant”) respectfully request the Court to extend the time for Defendant to file her response to

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Plaintiff’s Motion For Summary Judgment and Memorandum of Points and Authorities, due on
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December 20, 2017, by 45 days, through and including February 5, 2018 (the 45th day falls on
Saturday, February 3).

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Pursuant to Civil L.R. 6-2, the undersigned states the following:

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(1) An extension of time is needed as Defendant’s counsel is in the process of contacting his

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client, the Office of Hearing Operations (OHO) for the purposes of seeking settlement authority in this

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case.
(2) The undersigned is requesting a 45-day extension to insure the necessary time for

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discussion with OHO, and for them to provide a response within the next 30 days. Further the

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undersigned has 10 other district court briefs due in January.

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(3) Finally, the respective counsels will need additional time to negotiate the terms of any

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settlement.
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(3) Plaintiff’s Reply brief, if necessary will be due on February 20, 2018.

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(4) Pursuant to the Court’s scheduling order (ECF Doc. #4), the matter will be submitted for

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decision without oral argument, thus an extension of time will not require vacating a hearing date.

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(5) Counsel for Defendant conferred with Plaintiff’s counsel by email, who has no opposition to

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the requested extension on December 13, 2017.
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Stipulation re: extension, 4:17-cv-01473-KAW

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(6) This request is made in good faith with no intention to unduly delay the proceedings.

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Respectfully submitted,
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BRIAN J. STRETCH
United States Attorney

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Dated: December 14, 2017

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By: /s/Richard M. Rodriguez
RICHARD M. RODRIGUEZ
Special Assistant United States Attorney
Attorney for Defendant

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Dated: December 14, 2017

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/s/Jared T. Walker
JARED T. WALKER, CSBN 269029
Attorney for Plaintiff*
By Richard M. Rodriguez
(*email authorization on December 13, 2017)

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PURSUANT OT STIPULATION, IT IS SO ORDERED.

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12/19/17
Dated: _________________

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___________________________________
Hon. KANDIS WESTMORE
United States Magistrate Judge

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Stipulation re: extension, 4:17-cv-01473-KAW

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