Dixon v. Berryhill

Filing 22

ORDER by Judge Haywood S. Gilliam, Jr. Granting 21 Stipulation for Extension of Time. (ndrS, COURT STAFF) (Filed on 12/7/2018)

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ALEX G. TSE, CSBN 152348
United States Attorney
DEBORAH LEE STACHEL, CSBN 230138
Regional Chief Counsel, Region IX
Social Security Administration
MARGARET BRANICK-ABILLA, CSBN 223600
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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Attorneys for Defendant

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UNITED STATES DISTRICT COURT

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NORTHERN DISTRICT OF CALIFORNIA

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TERRANCE DIXON,

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Plaintiff,

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vs.

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NANCY A. BERRYHILL,
Acting Commissioner of Social Security,
Defendant.

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Case no. 4:18-cv-03483-HSG
STIPULATION AND ORDER FOR
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 45-day extension of time, from December
13, 2018 to January 27, 2019, for Defendant to respond to Plaintiff’s Motion for Summary Judgment.
All other dates in the Court’s Scheduling Order shall be extended accordingly.
This is Defendant’s first request for an extension of time. Defendant respectfully submits that
good cause exists for the requested extension because Defendant’s counsel was out of the office
unexpectedly and requires additional time to complete her review and analysis of the record and the
issues raised in Plaintiff’s motion, to determine whether options exist for settlement, and to prepare
Stipulation
Case no. 4:18-cv-03483-HSG
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Defendant’s response if settlement is not possible. Defendant’s counsel also has a number of other

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briefs due as well as an imminent hearing, and requires additional time to manage competing workload

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

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Plaintiff does not oppose the requested extension.

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Respectfully submitted,

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Dated: December 6, 2018

HOMELESS ACTION CENTER

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By:

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/s/ Suzanne Zalev*
SUZANNE ZALEV
Attorneys for Plaintiff
[*As authorized by email on Dec. 6, 2018]

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Dated: December 7, 2018

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ALEX G. TSE
United States Attorney
By:

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/s/ Margaret Branick-Abilla
MARGARET BRANICK-ABILLA
Special Assistant United States Attorney
Attorneys for Defendant

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ORDER

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Pursuant to stipulation, IT IS SO ORDERED.

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Dated: December 7, 2018

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HON. HAYWOOD S. GILLIAM, JR.
United States Magistrate Judge

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Stipulation
Case no. 4:18-cv-03483-HSG
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