STIPULATION 1 (3:17-CV-93-KAW) 

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KATHERINE SIEGFRIED 

Law Office of Katherine Siegfried, Esq. 

1814 Franklin Street, Suite 700 

Oakland, California 94612 

Phone: (510) 465-0016 

Fax: (510) 465-0017 

kat@siegfriedlegal.com 

BRIAN J. STRETCH (CABN 163973) 

United States Attorney 

DEBORAH LEE STACHEL (CSBN 230138) 

Regional Chief Counsel, Region IX 

Social Security Administration 

BEATRICE NA (CABN 303390) 

Special Assistant United States Attorney 

160 Spear Street, Suite 800 

San Francisco, CA 94105 

Telephone: 415-977-8967 

Facsimile: 415-744-0134

UNITED STATES DISTRICT COURT 

NORTHERN DISTRICT OF CALIFORNIA 

ELSIE ELENA INIGUEZ, 

 Plaintiff, 

 vs. 

NANCY A. BERRYHILL, Acting Commissioner 

Of Social Security, 

 Defendant. 

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CIVIL NO. 3:17-CV-93-KAW 

JOINT STIPULATION AND 

PROPOSED ORDER FOR A THIRTY 

DAY EXTENSION TIME FOR 

PLAINTIFF TO FILE HER MOTION 

FOR SUMMARY JUDGMENT 

IT IS HEREBY STIPULATED, by and between Plaintiff Elsie Elena Iniguez (Plaintiff) and 

Defendant Commissioner of Social Security (Defendant), by and through their respective counsel of 

record, that Plaintiff shall have an extension of time of thirty (30) days to file Plaintiff’s Motion For 

Summary Judgment. The current due date is August 21, 2017. The new due date will be September 20, 

2017. This is the first extension of time requested by Plaintiff. Plaintiff now must request this extension 
STIPULATION 2 (3:17-CV-93-KAW) 

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because Plaintiff’s counsel is a solo practitioner, did not represent Plaintiff at the administrative hearing 

and as there are over 1600 pages in the administrative record needs additional time to prepare the 

Motion for Summary Judgment. Additionally, Plaintiff’s counsel will be out of the office on a 

previously planned trip from August 9, 2017 until August 15, 2017. She also has two additional federal 

court briefs due by August 21, 2017. 

The parties further stipulate that the Court’s Scheduling Order shall be modified accordingly, 

with September 20, 2017 set for Plaintiff’s Motion for Summary Judgment, October 20, 2017 for 

Defendant’s Cross Motion/Motion for Summary Judgment and November 3, 2017 for Plaintiff’s Reply. 

Date: August 8, 2017 KATHERINE SIEGFRIED 

 Law Office of Katherine Siegfried, Esq. 

 By: /s/ Katherine Siegfried* 

 Katherine Siegfried 

 Attorney for the Plaintiff 

 

Date: August 8, 2017 BRIAN STRETCH 

 United States Attorney 

 

 By: /s/Beatrice Na 

 Beatrice Na 

 Special Assistant United States Attorney 

 Attorney for Defendant 

 (As authorized per email) 

 

* I hereby attest that I have on file all holograph 

signatures for any signatures indicated by a 

"conformed" signature (/S/) within this e-filed 

document.
STIPULATION 3 (3:17-CV-93-KAW) 

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ORDER

PURSUANT TO STIPULATION, IT IS SO ORDERED. 

Dated:________________________ _________________________________ 

 HON. KANDIS A. WESTMORE 

 UNITED STATES MAGISTRATE JUDGE 

8/11/17