Chang v. Commissioner of Social Security

Filing 20

STIPULATION and ORDER to Extend Briefing Schedule signed by Magistrate Judge Erica P. Grosjean on 1/27/2016. (Martinez, A)

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BENJAMIN B. WAGNER
United States Attorney
DEBORAH LEE STACHEL
Acting Regional Chief Counsel, Region IX
Social Security Administration
ASIM H. MODI, NY SBN 4692018
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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MAI CHANG,

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Plaintiff,

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v.

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CAROLYN W. COLVIN
Acting Commissioner of Social Security,

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Defendant.

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) Case No. 1:15-cv-0310-EPG
)
) 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 opening brief by 35 days to March 2,

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2016, and that all other scheduling dates set forth in the Court’s Case Management Order shall

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be extended accordingly. This is Defendant’s second request for an extension of time in this

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matter.1

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The Commissioner first sought an extension in this case because the Social Security
Administration’s Office of Disability Adjudication and Review was unable to prepare a complete
certified administrative record.
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There is good cause for this extension because counsel for Defendant requires additional

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time to properly consider and research the issues presented in Plaintiff’s opening brief.

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Furthermore, additional time is required because counsel for Defendant is responsible for

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drafting various pleadings before the district courts within the Ninth Circuit, negotiating or

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litigating attorney fee matters pursuant to the Equal Access to Justice Act, and conducting

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discovery in a personnel-related litigation matter pending before the Equal Employment

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Opportunity Commission.

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Counsel for Defendant apologizes to the Court for any inconvenience caused by this
delay.

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Respectfully submitted,

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Date: January 26, 2016

LAW OFFICES OF LAWRENCE D.
ROHLFING

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By:
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/s/ Asim H. Modi for Monica Perales*
MONICA PERALES
*Authorized by email on January 26, 2016
Attorneys for Plaintiff

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Date: January 26, 2016

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

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By:

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

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ORDER

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Pursuant to the parties’ stipulation (Doc. 19), the Commissioner’s response to Plaintiff’s

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opening brief shall be filed no later than March 2, 2016. Any reply may be filed within fifteen

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days of the filing of the opposition.

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IT IS SO ORDERED.
Dated:

January 27, 2016

/s/
UNITED STATES MAGISTRATE JUDGE

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