Qualls v. Commissioner of Social Security

Filing 24

STIPULATION and ORDER to Extend Time, signed by Magistrate Judge Barbara A. McAuliffe on 11/25/2019. (Valdez, E)

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McGREGOR W. SCOTT
United States Attorney
DEBORAH L. STACHEL
Regional Chief Counsel, Region IX,
Social Security Administration
TIMOTHY R. BOLIN, CSBN 259511
Special Assistant United States Attorney
Social Security Administration
Office of the General Counsel
160 Spear St Ste 800
San Francisco, CA 94105
Telephone: [phone]
Facsimile: [phone]
Email: [e-mail]
Attorneys for Defendant

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UNITED STATES DISTRICT COURT
EASTERN DISTRICT OF CALIFORNIA
(FRESNO)

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SHERI LEANNE QUALLS,

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Plaintiff,

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v.

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ANDREW SAUL,
Commissioner of Social Security,
Defendant.

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) No. 1:14-cv-02055-BAM
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) STIPULATION AND ORDER TO EXTEND
) TIME
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IT IS HEREBY STIPULATED by the parties, through their undersigned attorneys, to extend
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the time by 30 days, to December 23, 2019, for Defendant to file his response to Plaintiff’s Counsel’s
Motion for Attorney Fees (CR 20). Defendant respectfully requests this extension to enable

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additional time to research the amount of Plaintiff’s past-due benefit award. This has been

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complicated by the passage of time since the award, and the lack of staffing due to the

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impending holiday.

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Extend Stip; 1:14-cv-02055-BAM

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The parties further stipulate that any subsequent reply by Plainiff or her Counsel shall be
modified accordingly.

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Respectfully submitted,

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Date: November 22, 2019

Cerney Kreuze & Lott, LLP

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By:

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/s/ Shellie Lott*
SHELLIE LOTT
*By email authorization
Attorney for Plaintiff

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Date: November 22, 2019

McGREGOR W. SCOTT
United States Attorney
DEBORAH L. STACHEL
Regional Chief Counsel, Region IX,
Social Security Administration

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By:

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/s/ Timothy R. Bolin
TIMOTHY R. BOLIN
Special Assistant United States Attorney
Attorneys for Defendant

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Extend Stip; 1:14-cv-02055-BAM

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ORDER

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Based upon the parties’ stipulation, and good cause appearing, Defendant’s response to
Plaintiff’s motion for attorney’s fees pursuant to the Equal Access to Justice Act (Doc. 20), which is
currently due on or before December 9, 2019 (Doc. 22), shall be filed by December 23, 2019.
Plaintiff’s reply, if any, shall be filed on or before January 6, 2020. Counsel for the parties is
reminded that they are strongly encouraged to meet and confer and resolve this motion without
further Court involvement.

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IT IS SO ORDERED.
Dated:

/s/ Barbara

November 25, 2019

A. McAuliffe

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UNITED STATES MAGISTRATE JUDGE

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Extend Stip; 1:14-cv-02055-BAM

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