Knight v. Commissioner of Social Security

Filing 21

STIPULATION and ORDER GRANTING the parties' request for an extension of time to 6/26/2015 for receipt of defendant's responsive brief, with all other dates modified, accordingly. Order signed by Magistrate Judge Sandra M. Snyder on 6/19/2015. (Rooney, M)

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BENJAMIN B. WAGNER
United States Attorney
DONNA L. CALVERT
Regional Chief Counsel, Region IX
BRENDA M. PULLIN
Special Assistant United States Attorney
Social Security Administration

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160 Spear Street, Suite 800
San Francisco, California 94105
Telephone: [phone]
Facsimile: [phone]
E-Mail: [e-mail]
Attorneys for Defendant

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UNITED STATES DISTRICT COURT

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EASTERN DISTRICT OF CALIFORNIA

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FRESNO DIVISION

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Plaintiff,
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v.
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CAROLYN W. COLVIN, Acting Commissioner )
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of Social Security,
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Defendant.
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PAIGE ELLIS KNIGHT,

CASE NO. 1:14-CV-1276-SMS
STIPULATION AND ORDER FOR FIRST
EXTENSION OF TIME FOR DEFENDANT
TO FILE RESPONSIVE BRIEF

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IT IS HEREBY STIPULATED, by and between the parties, through their respective counsel
of record, that Defendant shall have a first extension of time of 30 days to respond to Plaintiff’s
opening brief. The extension is necessary as this case was not originally assigned to the undersigned
defense counsel, but rather was transferred to her in the midst of the merits briefing (see Doc. No.
19). Upon its transfer, new defense counsel was under the impression that the formerly assigned

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attorney had already requested an extension for filing the responsive brief. However, such an
extension appears not to have been filed.
Defendant respectfully suggests that this constitutes excusable neglect due to the volume of

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cases and administrative tasks handled by defense counsel. For these reasons, Defendant requests a
30-day extension of time to respond to Plaintiff’s opening brief.
There have been two prior extensions of time in this case, each extending the time for Plaintiff

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to file her opening brief (Doc. Nos. 15, 17). Defendant’s responsive brief was previously due on or

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before May 27, 2015; the new deadline would be June 26, 2015. The parties further stipulate that the

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Court’s Scheduling Order shall be modified accordingly.

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Dated: June 18, 2015

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By: /s/ Jacqueline A. Forslund
(as authorized via e-mail)
JACQUELINE A. FORSLUND
Attorney for Plaintiff

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BENJAMIN B. WAGNER
United States Attorney

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Dated: June 18, 2015

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By: s/ Brenda M. Pullin
BRENDA M. PULLIN
Special Assistant U.S. Attorney
Attorneys for Defendant

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ORDER
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PURSUANT TO STIPULATION, IT IS SO ORDERED.
DATED: 6/19/2015

/s/ SANDRA M. SNYDER
UNITED STATES MAGISTRATE JUDGE

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