People With Disabilities Foundation v. Berryhill

Northern District of California, cand-4:2015-cv-02570

ORDER by Judge Haywood S. Gilliam, Jr. Granting {{15}} Stipulation Continuing Deadline for Responsive Pleading and Initial Case Management Conference.

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1 MELINDA HAAG (CABN 132612) United States Attorney 2 ALEX G. TSE (CABN 152348) 3 Chief, Civil Division 4 ANN MARIE REDING (CABN 226864) Assistant United States Attorney 5 450 Golden Gate Avenue, Box 36055 6 San Francisco, California 94102-3495 Telephone: (415) 436-6813 7 FAX: (415) 436-6748 annie.reding@usdoj.gov 8 Attorneys for Defendant 9 10 UNITED STATES DISTRICT COURT 11 NORTHERN DISTRICT OF CALIFORNIA 12 SAN FRANCISCO DIVISION 13 PEOPLE WITH DISABILITIES, INC.,) CASE NO. 3:15-CV-02570-HSG 14) Plaintiff,) STIPULATION AND ORDER CONTINUING 15) DEADLINE FOR RESPONSIVE PLEADING AND v.) INITIAL CASE MANAGEMENT CONFERENCE 16) CAROLYN COLVIN, Acting Commissioner of) 17 Social Security,)) 18 Defendant.) 19 20 People with Disabilities, Inc. ("Plaintiff") and Defendant Carolyn Colvin, Acting Commissioner 21 of Social Security ("Defendant"), by and through their respective counsel, make the following 22 representations and stipulate and agree as follows: 23 1. On June 9, 2015, Plaintiff filed its Complaint in this action. See Dkt. No. 1. 24 2. On June 29, 2015, the U.S. Attorney's Office received a copy of Plaintiff's Complaint by 25 certified mail. See Declaration of Ann Marie Reding ("Reding Decl."), ¶ 2. 26 3. On July 15, 2015, this case was set for an initial case management conference before 27 Judge Haywood S. Gilliam for September 29, 2015, at 2:00 p.m., with a case management conference 28 STIPULATION AND PROPOSED ORDER Case No. 3:15-cv-02570-HSG 1 statement due to be filed on September 22, 2015. See Dkt. No. 14. 2 4. On August 10, 2015, Defendant requested a 30-day extension of time to respond to 3 Plaintiff's Complaint, to which Plaintiff agreed. Reding Decl. ¶ 3. 4 5. In light of Defendant's request, the parties stipulate and agree that Defendant's response 5 to Plaintiff's Complaint will be due on September 28, 2015. Id. at ¶ 4. 6 6. The parties further request that the initial case management conference be continued from 7 September 29, 2015 to November 10, 2015 at 2:00 p.m. This continuance will allow enough time for a 8 hearing on Defendant's motion to dismiss prior to the initial case management conference, should Defendant 9 decide to file a motion in response to Plaintiff's Complaint. Id. at ¶ 5. 10 7. No prior extensions of time have been requested or granted. See id. at ¶ 6. 11 8. The only effect the requested time modification will have on this case is to delay the initial 12 case management conference for six weeks. Id. 13 14 DATED: August 10, 2015 Respectfully submitted, 15 ____/s/ Steven F. Bruce______________ STEVEN F. BRUCE 16 Attorney for Plaintiff 17 People with Disabilities Foundation, Inc. 18 DATED: August 10, 2015 Respectfully submitted, 19 MELINDA HAAG United States Attorney 20 21 ___/s/ Ann Marie Reding 1____________________ ANN MARIE REDING 22 Assistant United States Attorney Attorneys for Defendant 23 24 25 26 1 27 I, Ann Marie Reding, hereby attest that I obtained the concurrence in the filing of this document of all signatories whose signatures are represented by /s/. 28 STIPULATION AND PROPOSED ORDER Case No. 3:15-cv-02570-HSG 1 ORDER 2 Plaintiff and Defendant's Stipulation and Proposed Order Continuing Deadline for Defendant's 3 Responsive Pleading and Initial Case Management Conference is hereby GRANTED. Defendant shall 4 file her responsive pleading to Plaintiff's Complaint or before September 28, 2015. The initial case 5 management scheduled for September 29, 2015, has been continued to November 10, 2015 at 2:00 p.m. 6 Date: August 12, 2015 7 _________________________ 8 HAYWOOD S. GILLIAM, JR. United States District Judge 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 STIPULATION AND PROPOSED ORDER Case No. 3:15-cv-02570-HSG