Johnson v. Berryhill

Filing 18

STIPULATION AND ORDER re 17 . STIPULATION WITH PROPOSED ORDER TO EXTEND DEADLINE filed by Howard L. Johnson, Nancy A. Berryhill. Motions to be filed by 10/11/2018. Signed by Magistrate Judge Kandis A. Westmore on 8/21/18. (sisS, COURT STAFF) (Filed on 8/21/2018)

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Dennis L. Kennelly, (SBN 064916)
Law Office of Dennis L. Kennelly
9107 Wilshire Blvd., Suite 450
Beverly Hills, CA 90210
Phone: [phone]
Fax: [phone]
Email: [e-mail]
Attorney for Plaintiff Howard L. Johnson

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UNITED STATES DISTRICT COURT
NORTHERN CALIFORNIA
OAKLAND DIVISION

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HOWARD L. JOHNSON,
PLAINTIFF, CASE NO.: 18-CV-00921 KAW
VS.
NANCY BERRYHILL, ACTING
COMMISSIONER OF SOCIAL SECURITY
ADMINISTRATION, DOES 1 THROUGH X,
ROES 1 THROUGH X,
DEFENDANT(S)

SECOND STIPULATION AND [PROPOSED]
ORDER FOR AN EXTENSION TO FILE
PLAINTIFF’S MOTION FOR SUMMARY
JUDGMENT.

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Pursuant to Federal Rule of Civil Procedure Rule 16(b)(4). Plaintiff Howard L.

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Johnson (“Plaintiff”) and Defendant Nancy Berryhill, et al (“Defendants”) hereby

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stipulate and agree as follows:

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WHEREAS, the Motion for Summary Judgment, currently due on or about
August 27, 2018 be extended for 45 days;

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Counsel for the Plaintiff has sent 2 facsimiles, on July 12th and July 22nd to

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the Defendant’s number [phone] requesting the information below, and as of

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this date still have not received the information requested.

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WHEREAS, the Plaintiff requests that the Defendants provide to the Plaintiff

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and the Plaintiff’s Counsel a full and complete copy of the Audio recording of October

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30, 2015, to include the Pre-Hearing, Hearing and Post-Hearing as soon as the CDs

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can be produced and the Audio provided be in .MP3 format.
SECOND STIPULATION AND [PROPOSED] ORDER FOR AN EXTENSION TO FILE
PLAINTIFF’S MOTION FOR SUMMARY JUDGMENT. – Pg 1

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For the Purpose of Expediency of review, the Plaintiff’s address is as follows:
Howard L. Johnson
1161 Willow Road, Apt 5
Menlo Park, CA 94025

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NOW, THEREFORE, THE PARTIES HEREBY STIPULATE AND AGREE, and

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based on the foregoing circumstances, request that the Court establish the following

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modified deadlines:

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

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The Plaintiff’s Motion for Summary Judgment scheduled for August 27,
2018 is continued to October 11, 2018.

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The remainder of DOC 3, Procedural Orders 3, 4 & 5 remain in effect.

Date: August 20, 2018

Law Office of Dennis L. Kennelly

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/s/ Dennis L. Kennelly_________________
Dennis L. Kennelly
Attorney for Plaintiff, Howard L. Johnson

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Date: August 20, 2018
/s/ Francesco P. Benavides____________
Francesco P. Benavides
Attorney for Defendant

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GOOD CAUSE APPEARING THEREFORE, IT IS SO ORDERED:
The deadline for filing Plaintiff’s Motion for Summary Judgment is extended to
October 11, 2018.
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Dated: August ___, 2018

____________________________________
Kandis A. Westmore
United States District Magistrate Judge

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SECOND STIPULATION AND [PROPOSED] ORDER FOR AN EXTENSION TO FILE
PLAINTIFF’S MOTION FOR SUMMARY JUDGMENT. – Pg 2