Ramirez v. Commissioner of Social Security

Filing 16

STIPULATION and ORDER to Extend Briefing Schedule signed by Magistrate Judge Gary S. Austin on 12/31/2013. (Martinez, A)

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BOBBIE J. MONTOYA
Assistant United States Attorney
DONNA L. CALVERT
Acting Regional Chief Counsel, Region IX
Social Security Administration
SUSAN L. SMITH
Special Assistant United States Attorney
160 Spear Street, Suite 800
San Francisco, California 94105
Telephone: [phone]
Facsimile: [phone]
Email: [e-mail]

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Attorneys for Defendant
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UNITED STATES DISTRICT COURT
EASTERN DISTRICT OF CALIFORNIA
FRESNO DIVISION

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MARIA M. RAMIREZ

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Plaintiff,
v.
CAROLYN W. COLVIN, Acting
Commissioner of Social Security,

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Defendant.

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) Case No.: 1:13-CV-00513-GSA
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) STIPULATION AND ORDER TO EXTEND
) BRIEFING SCHEDULE
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IT IS HEREBY STIPULATED by the parties, through their undersigned attorneys, that
Defendant shall have a first extension of time of fourteen (14) days, from December 23, 2013 to
January 6, 2013, to file her response to Plaintiff’s opening brief. This is Defendant’s first request
for an extension.
Defense counsel mistakenly overlooked the fact that Plaintiff filed her brief eight days
early, thereby adjusting the briefing schedule. Moreover, notwithstanding the return of all
attorneys subsequent the September 2013 furlough, the Office of the General Counsel for the
Social Security Administration has a substantial backlog of work as a result of the lapse in
appropriations. The Office of the General Counsel is working diligently to prioritize and work
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through this backlog as efficiently as possible. As such, the Acting Commissioner requests a 14-

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day extension of time for filing the Commissioner’s brief, with all other dates in the Court’s CMO

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to be extended accordingly.
Respectfully submitted,

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Date: December 31, 2013

/s/Christopher Dellert for Kelsey Mackenzie Brown
KELSEY MACKENZIE BROWN
Dellert Baird Law Office, PLLC
Attorneys for Plaintiff
*By email authorization on December 24, 2013

Date: December 31, 2013

BENJAMIN B. WAGNER
United States Attorney

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By:

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/s/Susan L. Smith
SUSAN L. SMITH
Special Assistant U.S. Attorney
Attorneys for Defendant

Of Counsel
Tina Saladino
Assistant Regional Counsel
Social Security Administration

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ORDER

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Pursuant to the above stipulation, Defendant’s Opposition shall be filed no later than

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January 6, 2014. All other deadlines outlined in this Court’s scheduling order shall be modified
accordingly.

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IT IS SO ORDERED.
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Dated:

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December 31, 2013

/s/ Gary S. Austin
UNITED STATES MAGISTRATE JUDGE

DEAC_Signature-END:

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