Bernal v. Commissioner of Social Security

Filing 20

STIPULATION and ORDER GRANTING the parties' request for an extension of time to 8/5/2015 for receipt of defendant's response to plaintiff's motion for attorney fees. Order signed by Magistrate Judge Barbara A. McAuliffe on 7/2/2015. (Rooney, M)

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BENJAMIN B. WAGNER
United States Attorney
DONNA L. CALVERT
Regional Chief Counsel, Region IX
Social Security Administration
ASIM H. MODI
Special Assistant United States Attorney
Social Security Administration
160 Spear Street, Suite 800
San Francisco, CA 94105
Telephone: [phone]
Facsimile: 415-744-0134
Email: [e-mail]
Attorneys for Defendant
UNITED STATES DISTRICT COURT
EASTERN DISTRICT OF CALIFORNIA
FRESNO DIVISION

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RICHARD FRANK BERNAL,
Plaintiff,

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

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Defendant.

) Case No. 1:13-cv-0707-BAM
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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, to

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extend Defendant’s time to file her response to Plaintiff’s Motion for Attorney Fees with the

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Court by 30 days to August 5, 2015, and that all other scheduling dates set forth in the Court’s

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Case Management Order shall be extended accordingly. This is Defendant’s first request for an

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extension of time in this matter.

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There is good cause for this extension because counsel for Defendant will be on leave for

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portions of the next two weeks. There is also good cause for this extension because counsel for

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Defendant is currently responsible for numerous district court cases at various stages of

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litigation, as well as conducting discovery and preparing substantive motions in proceedings

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before the Equal Employment Opportunity Commission and Merit Systems Protection Board.

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Respectfully submitted,

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Date: June 23, 2015

LAW OFFICES OF HELEN R. ZNE
By:

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Date: June 23, 2015

/s/ Asim H. Modi for Helen R. Zane*
HELEN R. ZANE
*Authorized by email on June 23, 2015
Attorneys for Plaintiff
BENJAMIN B. WAGNER
United States Attorney
DONNA L. CALVERT
Regional Chief Counsel, Region IX
Social Security Administration

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By:

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/s/ Asim H. Modi
ASIM H. MODI
Special Assistant United States Attorney
Attorneys for Defendant

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ORDER

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Based upon the stipulation of the parties, and for cause shown, IT IS HEREBY

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ORDERED that the Defendant’s deadline to file a response to Plaintiff’s Motion for Attorney is

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extended to August 5, 2015.

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IT IS SO ORDERED.

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Dated:

/s/ Barbara

July 2, 2015

A. McAuliffe

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UNITED STATES MAGISTRATE JUDGE

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