Pang v. Commissioner of Social Security

Filing 18

STIPULATION and ORDER for Extension of Briefing Schedule: that Defendant shall have an extension of time, to and including October 30, 2015, in which to file an opposition to Plaintiffs Opening Brief; and that all other deadlines set forth in the July 24, 2014 Case Management Order shall be extended accordingly. signed by Magistrate Judge Barbara A. McAuliffe on 9/29/2015. (Herman, H)

1
2
3
4
5
6
7
8
9
10
11
12
13
14
15

STEVEN GILBERT ROSALES
Law Offices of Lawrence D. Rohlfing
12631 East Imperial Highway
Suite C-115
Santa Fe Springs, CA 90670
Telephone: [phone]
Fax: [phone]
[e-mail]
Attorney for Plaintiff
BENJAMIN B. WAGNER
United States Attorney
DEBORAH LEE STACHEL
Acting Regional Chief Counsel, Region IX
Social Security Administration
LARA A. BRADT, CSBN 289036
Special Assistant United States Attorney
Social Security Administration
160 Spear St., Suite 800
San Francisco, CA 94105
Telephone: [phone]
Facsimile: [phone]
Email: [e-mail]
Attorneys for Defendant

16
17
UNITED STATES DISTRICT COURT
EASTERN DISTRICT OF CALIFORNIA
FRESNO DIVISION

18
19
20

THOMAS PANG,

21
22
23
24
25

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

)
)
)
)
)
)
)
)
)
)

No. 1:14-cv-01122-BAM
STIPULATION AND ORDER FOR
EXTENSION OF BRIEFING
SCHEDULE

26

Defendant.

27

The parties stipulate through counsel to extend the time for Defendant to file her

28

responsive brief in this case until October 30, 2015. This case recently was assigned to the

Stip. for Extension of Briefing Schedule, No. 1:14-cv-01122-BAM

1

undersigned counsel for Defendant, who notes that the Acting Commissioner’s brief is overdue.

2

Defendant’s opposing brief was due on July 23, 2015. Counsel for Defendant submits that a

3

logistical error occurred in managing the case. For purposes of workload distribution, this case

4

was slated for reassignment from former counsel of record for the government to another

5

attorney in the Office of General Counsel for the Social Security Administration, Region IX.

6

However, as a result of an oversight, no reassignment occurred until the week of this submission,

7

and Defendant inadvertently missed the briefing deadline. Counsel for Defendant requests this

8

extension to remedy this error and allow the newly assigned counsel of record to become

9

familiar with the case and prepare Defendant’s brief.
Although two previous extensions have been entered in this case, this is Defendant’s first

10
11

request for an extension of time, and it is sought in good faith.

12
13

Date: September 28, 2015

14
15

By:

/s/Steven Rosales*
*as authorized by email on Sept. 25, 2015
STEVEN GILBERT ROSALES
Law Offices of Lawrence D. Rohlfing
Attorney for Plaintiff

16
17
18

Date: September 28, 2015

19
20

BENJAMIN B. WAGNER
United States Attorney
DEBORAH LEE STACHEL
Acting Regional Chief Counsel, Region IX
Social Security Administration
By: /s/ Lara A. Bradt
LARA A. BRADT
Special Assistant United States Attorney
Attorneys for Defendant

21
22
23
24
25

///

26

///

27

///

28

///

-2-

ORDER

1
2

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

3

ORDERED, that Defendant shall have an extension of time, to and including October 30, 2015,

4

in which to file an opposition to Plaintiff’s Opening Brief; and that all other deadlines set forth in

5

the July 24, 2014 Case Management Order shall be extended accordingly.

6
7

IT IS SO ORDERED.

8
Dated:
9

/s/ Barbara

September 29, 2015

A. McAuliffe

_

UNITED STATES MAGISTRATE JUDGE

10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28

-3-