Bushnell v. Berryhill

Filing 17

***PLEASE SEE EXECUTED COPY AT ECF NO. 18 ***ORDER GRANTING 16 STIPULATION TO EXTEND DEADLINE. Signed by Judge Edward J. Davila on 10/6/2017. (ejdlc2S, COURT STAFF) (Filed on 10/6/2017) Modified on 10/6/2017 (ofr, COURT STAFF).

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BRIAN J. STRETCH, CSBN 163973
United States Attorney
DEBORAH LEE STACHEL
Regional Chief Counsel, Region IX
Social Security Administration
CHANTAL R. JENKINS, SBN PA 307531
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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SHAREE BUSHNELL,
Plaintiff,
vs.

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

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CIVIL NO. 5:17-cv-02718-EJD
STIPULATION & PROPOSED ORDER
FOR EXTENSION FOR DEFENDANT
TO RESPOND TO PLANTIFF’S
MOTION FOR SUMMARY
JUDGMENT

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IT IS HEREBY STIPULATED by and between the parties that Defendant shall have an

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extension of time to November 9, 2017 to respond to Plaintiff’s motion for summary judgment. This is

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Defendant’s first request for an extension of time. Since Plaintiff’s counsel filed her brief, Defendant’s

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counsel has been working on discovery in an Equal Employment Opportunity Commission (EEOC)

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case and responding to an appeal of another EEOC case. Defendant’s counsel will be out of the office

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for the first couple weeks of October and has several other district court briefs due in October and

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November.

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

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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: October 5, 2017

/s/ Terry LaPorte, Esq.*
*(as authorized via email on October 5, 2017)
Terry LaPorte, Esq.

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BRIAN J. STRETCH
United States Attorney

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Dated: October 5, 2017

/s/ Chantal R. Jenkins
Chantal R. Jenkins
Special Assistant U.S. Attorney

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Attorneys for Defendant

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ORDER

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PURSUANT TO STIPULATION, IT IS SO ORDERED.
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DATED:________________________

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HON. EDWARD J. DAVILA
UNITED STATES DISTRICT JUDGE

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