Chang v. Commissioner of Social Security

Filing 22

STIPULATION and ORDER GRANTING the parties' request for an extension of time to 3/30/2016 for receipt of defendant's opposition brief, with plaintiff's optional reply due by 4/14/2016. Order signed by Magistrate Judge Erica P. Grosjean on 3/2/2016. (Rooney, M)

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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,
Plaintiff,

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

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Defendant.

) Case No. 1:15-cv-0310-EPG
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) 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 28 days to March 30,

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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.

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On January 28, 2016, the parties stipulated to an extension of the briefing schedule to

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allow counsel for Defendant additional time to properly consider and research the issues

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presented in Plaintiff’s opening brief. However, there is good cause for this extension because

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Defendant is currently pursuing the possibility of settlement and voluntary remand in this case.

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Accordingly, Defendant needs additional time to prepare her responsive brief, if necessary. This

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request is made in good faith and is not intended to unnecessarily delay these proceedings.

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Counsel for Defendant sincerely apologizes to the Court and to Plaintiff for any inconvenience

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caused by this extension.

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Respectfully submitted,

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Date: March 1, 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 March 1, 2016
Attorneys for Plaintiff

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Date: March 1, 2016

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

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ORDER

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Based on the above stipulation, and good cause appearing therein, the Court grants

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Defendant an extension to file her opposition to Plaintiff’s opening brief. Defendant shall file her

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brief no later than March 30, 2016. Plaintiff may file her reply brief no later than April 14,

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2016.

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IT IS SO ORDERED.
Dated:

March 2, 2016

/s/
UNITED STATES MAGISTRATE JUDGE

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