Tahir v. Berryhill

Filing 22

ORDER by Judge Haywood S. Gilliam, Jr. Granting 21 Stipulation.Dispositive Motion due by 6/10/2019 and Cross Motions due by 7/18/2019. (ndrS, COURT STAFF) (Filed on 5/7/2019)

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DONALD H. MEDEARIS, SBN 206849
BAY AREA LEGAL AID
1800 Market Street, 3rd Floor
San Francisco, CA 94102
Telephone: [phone]
Fax: [phone]
[e-mail]
Attorney for Plaintiff,
SYED ABU TAHIR

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UNITED STATES DISTRICT COURT

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NORTHERN DISTRICT OF CALIFORNIA

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OAKLAND DIVISION

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SYED ABU TAHIR,

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Plaintiff,

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vs.

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NANCY A. BERRYHILL, Acting
Commissioner of the Social Security
Administration,

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Defendant.

Case No. 4:18-cv-03675-HSG
STIPULATION AND PROPOSED ORDER
FOR A SECOND EXTENSION OF TIME
FOR PLAINTIFF TO FILE MOTION FOR
SUMMARY JUDGMENT

IT IS HEREBY STIPULATED, by and between the parties, through their respective
counsel of record, that Plaintiff shall have a second extension of time of 28 days to file his

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Motion for Summary Judgment (MSJ) in response to Defendant’s Answer. The Court

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previously granted Plaintiff’s request for an extension of 60 days to file his MSJ, so that

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Plaintiff, who was then Pro Se, would have time to seek counsel. Plaintiff has now obtained
counsel and counsel substituted in as Plaintiff’s attorney today. Plaintiff’s attorney requests
an extension because he will be representing clients at two already-scheduled Social Security

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STIPULATION TO A SECOND EXTENSION OF TIME FOR PLAINTIFF TO FILE
MOTION FOR SUMMARY JUDGMENT, AND PROPOSED ORDER; CASE NO. 4:18CV-03675-HSG

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administrative hearings this Thursday, May 9, a Reply brief due in another United States
District Court case on May 10, 2019, and a heavy caseload.
The current due date for Plaintiff's Motion for Summary Judgment is Monday, May
13, 2019. The new due date for filing Plaintiff’s Motion for Summary Judgment would be
Monday, June 10, 2019. The Commissioner's Motion would then be due on or before
Monday, July 8, 2019.
Plaintiff and Plaintiff’s attorney sincerely apologize to the Court and to the Defendant
for any inconvenience caused by this delay. The parties further stipulate that the Court’s
Scheduling Order shall be modified accordingly.

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Respectfully submitted,

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Dated: 05/06/2019

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/s/ Donald H. Medearis
DONALD H. MEDEARIS
Attorney for Plaintiff

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Dated: 05/06/2019

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DAVID L. ANDERSON
United States Attorney
DEBORAH STACHEL,
Regional Chief Counsel Region IX
By: /s/ Sharon Lahey
(*as authorized by e-mail on 05/06/2019)
SHARON LAHEY,
Assistant Regional Counsel
Attorneys for Defendant

ORDER:
APPROVED AND SO ORDERED
Dated: ____________
5/7/2019

By: _______________________________
THE HONORABLE HAYWOOD S.
GILLIAM, JR.
United States District Judge

STIPULATION TO A SECOND EXTENSION OF TIME FOR PLAINTIFF TO FILE
MOTION FOR SUMMARY JUDGMENT, AND PROPOSED ORDER; CASE NO. 4:18CV-03675-HSG

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