Campos v. Berryhill

Filing 24

.STIPULATION AND ORDER GRANTING re 23 Second MOTION for Extension of Time to File Response/Reply filed by Nancy Berryhill, Jose Campos. Signed by Magistrate Judge Kandis A. Westmore on 2/7/18. (sisS, COURT STAFF) (Filed on 2/7/2018)

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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
GINA TOMASELLI
Special Assistant United States Attorney
160 Spear Street, Suite 800
San Francisco, California 94105
Telephone: [phone]
Facsimile: [phone]
E-Mail: [e-mail]
Attorneys for Defendant
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF CALIFORNIA (OAKLAND)

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Plaintiff,

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vs.

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) CIVIL NO. 4:17-cv-02770-KAW
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) STIPULATION AND [PROPOSED]
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) ORDER FOR EXTENSION OF TIME
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JOSE CAMPOS,

NANCY A. BERRYHILL,
Acting Commissioner of Social Security,

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Defendant.
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IT IS HEREBY STIPULATED, by and between Jose Campos (Plaintiff) and Nancy A. Berryhill,

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Acting Commissioner of Social Security (Defendant), by and through their respective counsel of record,

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that Defendant shall have an extension of time of fifteen (15) days to deliver her Motion for Summary

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Judgment and in Opposition to Plaintiff’s Motion for Summary Judgment. The current due date is

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February 8, 2018. The new due date will be February 23, 2018. The parties further stipulate that all

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other dates will be extended accordingly, and Plaintiff’s reply will be due to Defendant by March 23,

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2018.

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This is the second extension of time requested by Defendant in the above-captioned matter.

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Defendant respectful requests this extension because this case was recently transferred to another

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attorney who has not had sufficient time to fully consider the issues in this case, which involves a
Stip. & Prop. Order for Ext.; 17-2770

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sizeable administrative record. This request is made in good faith with no intention to unduly delay the
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proceedings. Counsel for Defendant conferred with Plaintiff’s counsel, who has no opposition to this
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motion, on February 7, 2018. It is therefore respectfully requested that Defendant be granted a fifteen
(15) day extension of time to respond to Plaintiff’s motion, up to and including February 22, 2018.

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Respectfully submitted,

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Dated: February 7, 2018

By: /s/ Nancy Katherine McCombs *
NANCY KATHERINE MCCOMBS
Attorney for Plaintiff
(*by email authorization on 2/7/2018)

Dated: February 7, 2018

Alex G. Tse
Acting United States Attorney

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By: /s/ Gina Tomaselli
GINA TOMASELLI
Special Assistant United States Attorney

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Attorneys for Defendant

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IT IS SO ORDERED:

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__________________________________
THE HONORABLE KANDIS A. WESTMORE
UNITED STATES MAGISTRATE JUDGE

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2/7/18
DATE:__________________________

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Stip. & Prop. Order for Ext.; 17-2770

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