Whaley v. CSS

Filing 17

Stipulation and Order for an extension of Thirty Days for Defendant to file her opposition to Plaintiff's Opening Brief, signed by Magistrate Judge Sandra M. Snyder on 8/13/2015. (Opening Brief Deadline: 9/18/2015) (Rosales, O)

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BENJAMIN B. WAGNER
United States Attorney
DEBORAH LEE STACHEL
Acting Regional Chief Counsel, Region IX
Social Security Administration
JENNIFER A. KENNEY, CSBN 241625
Special Assistant United States Attorney
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
EASTERN DISTRICT OF CALIFORNIA

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FRESNO DIVISION

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BILLY RAY WHALEY,

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Plaintiff,
vs.
CAROLYN W. COLVIN,
Acting Commissioner of Social Security,
Defendant.

Case No.: 1:14-CV-01719-SMS
STIPULATION AND ORDER FOR AN
EXTENSION OF 30 DAYS FOR
DEFENDANT TO FILE HER OPPOSITION
TO PLAINTIFF’S OPENING BRIEF

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IT IS HEREBY STIPULATED, by the parties, through their respective counsel of record,
that Defendant shall have an extension of time of 30 days to file her Opposition to Plaintiff’s

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Opening Brief. The parties previously stipulated to a two-week extension for Plaintiff to file his

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Opening Brief. This is Defendant’s first request for extension. The additional time is requested

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due to Defendant’s counsel’s exceptionally heavy workload at this time, including two

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employment law matters in active litigation, one pending before the pending Equal Employment

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Opportunity Commission, No. 540-2014-00176X, and one before the Merit Systems Protection
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Board, Docket No. CB-7521-14-0013-T-1. In addition, Defendant’s counsel has three other
Stip. & Prop. Order to Extend 1:14-CV-01719-SMS

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district court briefings and a 9th Circuit briefing due in the next week. The additional time

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requested is needed to adequately research the issues Plaintiff has presented. The current due

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date is August 19, 2015. The new due date will be September 18, 2015.

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The parties further stipulate that the Court’s Scheduling Order shall be modified
accordingly.
Counsel apologizes to the Court for any inconvenience caused by this delay.

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Respectfully submitted,

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Dated: August 12, 2015

/s/ *Monica Perales
(*as authorized by email on Aug. 12, 2015)
MONICA PERALES
Law Offices of Lawrence D. Rohlfing
Attorney for Plaintiff

Dated: August 12, 2015

BENJAMIN B. WAGNER
United States Attorney
DEBORAH LEE STACHEL
Acting Regional Chief Counsel, Region IX,
Social Security Administration

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By:

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/s/ Jennifer A. Kenney
JENNIFER A. KENNEY
Special Assistant U.S. Attorney
Attorneys for Defendant

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ORDER
APPROVED AND SO ORDERED:

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IT IS SO ORDERED.

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Dated:

August 13, 2015

/s/ Sandra M. Snyder
UNITED STATES MAGISTRATE JUDGE

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Stip. & Prop. Order to Extend 1:14-CV-01719-SMS

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